Introduction
1.1 We are committed to safeguarding the privacyof our website visitors and service users.
1.2 This policy applies where we are acting as adata controller with respect to the personal data of our website visitors andservice users; in other words, where we determine the purposes and means of theprocessing of that personal data.
1.3 We will ask you to consent to our use ofcookies in accordance with the terms of this policy when you first visit ourwebsite.
1.4 Our website incorporates privacy controlswhich affect how we will process your personal data. By using the privacycontrols, you can specify whether you would like to receive direct marketingcommunications and limit the publication of your information.
1.5 In this policy, “we”, “us” and “our” refer toLucavi. For more information about us, see Section 13.
3.0 How we use your personaldata
3.1 In this Section 3 we have set out:
(a) the general categories of personal data thatwe may process;
(b) in the case of personal data that we did notobtain directly from you, the source and specific categories of thatdata;
(c) the purposes for which we may processpersonal data; and
(d) the legal bases of the processing.
3.2 We may process data about your use of ourwebsite and services (“usage data“). The usage data may include your IPaddress, geographical location, browser type and version, operating system,referral source, length of visit, page views and website navigation paths, aswell as information about the timing, frequency and pattern of your serviceuse. The source of the usage data is our analytics tracking system. This usagedata may be processed for the purposes of analyzing the use of the website andservices. The legal basis for this processing is our legitimate interests, namelymonitoring and improving our website and services.
3.3 We may process your account data (“accountdata“).The account data may include your name and email address The source ofthe account data is you or your employer. The account data may be processed forthe purposes of operating our website, providing our services, ensuring thesecurity of our website and services, maintaining back-ups of our databases andcommunicating with you.
The legal basis for this processing is ourlegitimate interests, namely the proper administration of our website andbusiness.
3.4 We may process your information included inyour personal profile on our website (“profile data“). The profile data mayinclude your name, address, telephone number, email address, profile pictures,gender, date of birth, relationship status, interests and hobbies, educationaldetails and employment details. The profile data may be processed for thepurposes of enabling and monitoring your use of our website and services]. Thelegal basis for this processing is our legitimate interests, namely the properadministration of our website and business.
3.5 We may process your personal data that areprovided in the course of the use of our services (“service data“). The sourceof the service data is you or your employer. The service data may be processedfor the purposes of operating our website, providing our services, ensuring thesecurity of our website and services, maintaining back-ups of our databases andcommunicating with you. The legal basis for this processing is our legitimateinterests, namely the proper administration of our website andbusiness.
3.6 We may process information that you post forpublication on our website or through our services] (“publication data“). Thepublication data may be processed for the purposes of enabling such publicationand administering our website and services. The legal basis for this processingis our legitimate interests, namely the proper administration of our websiteand business.
3.7 We may process information contained in anyenquiry you submit to us regarding goods and/or services (“enquiry data“). Theenquiry data may be processed for the purposes of offering, marketing andselling relevant goods and/or services to you. The legal basis for thisprocessing is consent.
3.8 We may process information relating totransactions, including purchases of goods and services, that you enter intowith us and/or through our website (“transaction data“). The transaction datamay include your contact details, your card detailstransaction details. Thetransaction data may be processed for the purpose of supplying the purchasedgoods and services and keeping proper records of those transactions. The legalbasis for this processing is the performance of a contract between you and usand/or taking steps, at your request, to enter into such a contract and ourlegitimate interests, namely [our interest in the proper administration of ourwebsite and business.
3.9 We may process information that you provideto us for the purpose of subscribing to our email notifications and/ornewsletters] (“notification data“). The notification data may be processed forthe purposes of sending you the relevant notifications and/or newsletters. Thelegal basis for this processing is consent.
3.10 We may process information contained in orrelating to any communication that you send to us (“correspondence data“). Thecorrespondence data may include the communication content and metadataassociated with the communication. Our website will generate the metadataassociated with communications made using the website contact forms. Thecorrespondence data may be processed for the purposes of communicating with youand record-keeping. The legal basis for this processing is our legitimateinterests, namely the proper administration of our website and business andcommunications with users.
3.11 We may process your business data. This datamay include Business Name, Address, Email, Telehone. The source of this data isour Accounts System. The legal basis forthis processing is our legitimate interests, namely to run our business andprovide the required services to you or your business.
3.12 We may process any of your personal dataidentified in this policy where necessary for the establishment, exercise ordefence of legal claims, whether in court proceedings or in an administrativeor out-of-court procedure. The legal basis for this processing is ourlegitimate interests, namely the protection and assertion of our legal rights,your legal rightslegal rights of others.
3.13 We may process any of your personal dataidentified in this policy where necessary for the purposes of obtaining ormaintaining insurance coverage, managing risks, or obtaining professionaladvice. The legal basis for this processing is our legitimate interests, namelythe proper protection of our business against risks.
3.14 In addition to the specific purposes forwhich we may process your personal data set out in this Section 3, we may alsoprocess any of your personal data where such processing is necessary forcompliance with a legal obligation to which we are subject, or in order toprotect your vital interests or the vital interests of another naturalperson.
3.15 Please do not supply any other person’spersonal data to us, unless we prompt you to do so.
4.0 Providing your personal data toothers.
4.1 We may disclose your personal data to anymember of our group of companies (this means our subsidiaries, our ultimateholding company and all its subsidiaries) insofar as reasonably necessary forthe purposes, and on the legal bases, set out in this policy.
4.2 We may disclose your personal data to [ourinsurers and/or professional advisers insofar as reasonably necessary for thepurposes of obtaining or maintaining insurance coverage, managing risks,obtaining professional advice, or the establishment, exercise or defence oflegal claims, whether in court proceedings or in an administrative orout-of-court procedure.
4.3 Wewill never disclose to your details to any third parties.
4.4 Financial transactions relating to ourwebsite and services are handled by our payment services providers, Paypal,Our Bank. We will share transaction datawith our payment services providers only to the extent necessary for thepurposes of processing your payments, refunding such payments and dealing withcomplaints and queries relating to such payments and refunds. You can findinformation about the payment services providers’ privacy policies andpractices at
https://www.paypal.com/ee/webapps/mpp/ua/privacy-full
https://www.hsbc.co.uk/1/2/privacy-notice
https://www.worldpay.com/uk/worldpay-privacy-notice
4.5 We will not disclose your enquiry data to anyselected third party suppliers of goods and services identified on our websitefor the purpose of enabling them to contact you so that they can offer, marketand sell to you relevant goods and/or services. Each such third party will actas a data controller in relation to the enquiry data that we supply to it; andupon contacting you, each such third party will supply to you a copy of its ownprivacy policy, which will govern that third party’s use of your personaldata.
4.6 In addition to the specific disclosures ofpersonal data set out in this Section 4, we may disclose your personal datawhere such disclosure is necessary for compliance with a legal obligation towhich we are subject, or in order to protect your vital interests or the vitalinterests of another natural person. We may also disclose your personal datawhere such disclosure is necessary for the establishment, exercise or defenceof legal claims, whether in court proceedings or in an administrative orout-of-court procedure.
5.0 International transfers of your personal data
5.1 In this Section 5, we provide informationabout the circumstances in which your personal data may be transferred tocountries outside the European Economic Area (EEA)].
5.2 We do not have any offices or facilities inany other countries. The EuropeanCommission has made an “adequacy decision” with respect to the data protectionlaws of each of these countries. Transfers to each of these countries will beprotected by appropriate safeguards, namely the use of standard data protectionclauses adopted or approved by the European Commission.
5.3 The hosting facilities for our website aresituated in The United Kingdom. The European Commission has made an “adequacydecision” with respect to the data protection laws of each of these countries.Transfers to each of these countries will be protected by appropriatesafeguards, namely the use of standard data protection clauses adopted orapproved by the European Commission.
5.4 You acknowledge that personal data that yousubmit for publication through our website or services may be available, viathe internet, around the world. We cannot prevent the use (or misuse) of suchpersonal data by others.
6.0 Retaining and deleting personaldata
6.1 This Section 6 sets out our data retentionpolicies and procedure, which are designed to help ensure that we comply withour legal obligations in relation to the retention and deletion of personaldata.
6.2 Personal data that we process for any purposeor purposes shall not be kept for longer than is necessary for that purpose orthose purposes.
6.3 We will retain your personal data asfollows:
(a) “Profile Data” and “Service Data” will be retained for a minimum period of 6Months following the closure of your services, and for a maximum period of 2Years following the closure of your services.
6.4 In some cases it is not possible for us tospecify in advance the periods for which your personal data will be retained. In such cases, we will determinethe period of retention based on the following criteria:
(a) the period of retention of “Profile Data” and“Service Data” will be determined based on HMRC Accounts StorageRequirements.
6.5 Notwithstanding the other provisions of thisSection 6, we may retain your personal data where such retention is necessaryfor compliance with a legal obligation to which we are subject, or in order toprotect your vital interests or the vital interests of another naturalperson.
7.0 Amendments
7.1 We may update this policy from time to timeby publishing a new version on our website.
7.2 You should check this page occasionally toensure you are happy with any changes to this policy.
7.3 We may notify you of changes to this policyby email or through the private messaging system on ourwebsite.
8.0 Your rights
8.1 In this Section 8, we have summarised therights that you have under data protection law. Some of the rights are complex,and not all of the details have been included in our summaries. Accordingly,you should read the relevant laws and guidance from the regulatory authoritiesfor a full explanation of these rights.
8.2 Your principal rights under data protectionlaw are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisoryauthority; and
(h) the right to withdraw consent.
8.3 You have the right to confirmation as towhether or not we process your personal data and, where we do, access to thepersonal data, together with certain additional information. That additionalinformation includes details of the purposes of the processing, the categoriesof personal data concernedrecipients of the personal data. Providing the rightsand freedoms of others are not affected, we will supply to you a copy of yourpersonal data. The first copy will be provided free of charge, but additionalcopies may be subject to a reasonable fee.
8.4 You have the right to have any inaccuratepersonal data about you rectified and, taking into account the purposes of theprocessing, to have any incomplete personal data about you completed.
8.5 In some circumstances you have the right tothe erasure of your personal data without undue delay. Those circumstancesinclude: [the personal data are no longer necessary in relation to the purposesfor which they were collected or otherwise processed; you withdraw consent toconsent-based processing; you object to the processing under certain rules ofapplicable data protection law; the processing is for direct marketingpurposes;personal data have been unlawfully processed]. However, there areexclusions of the right to erasure. The general exclusions include whereprocessing is necessary: for exercising the right of freedom of expression andinformation; for compliance with a legal obligation; or for the establishment,exercise or defence of legal claims.
8.6 In some circumstances you have the right torestrict the processing of your personal data. Those circumstances are: youcontest the accuracy of the personal data; processing is unlawful but youoppose erasure; we no longer need the personal data for the purposes of ourprocessing, but you require personal data for the establishment, exercise ordefence of legal claims; and you have objected to processing, pending theverification of that objection. Where processing has been restricted on thisbasis, we may continue to store your personal data. However, we will onlyotherwise process it: with your consent; for the establishment, exercise ordefence of legal claims; for the protection of the rights of another natural orlegal person; or for reasons of important public interest.
8.7 You have the right to object to ourprocessing of your personal data on grounds relating to your particularsituation, but only to the extent that the legal basis for the processing isthat the processing is necessary for: the performance of a task carried out inthe public interest or in the exercise of any official authority vested in us;or the purposes of the legitimate interests pursued by us or by a third party.If you make such an objection, we will cease to process the personalinformation unless we can demonstrate compelling legitimate grounds for theprocessing which override your interests, rights and freedoms, or theprocessing is for the establishment, exercise or defence of legalclaims.
8.8 Youhave the right to object to our processing of your personal data for directmarketing purposes (including profiling for direct marketing purposes). If youmake such an objection, we will cease to process your personal data for thispurpose.
8.9 Youhave the right to object to our processing of your personal data for scientificor historical research purposes or statistical purposes on grounds relating toyour particular situation, unless the processing is necessary for theperformance of a task carried out for reasons of public interest.
8.10 To the extent that the legal basis for ourprocessing of your personal data is:
(a) Consent; or
(b) that the processing is necessary for theperformance of a contract to which you are party or in order to take steps atyour request prior to entering into a contract,
and such processing is carried out by automatedmeans, you have the right to receive your personal data from us in astructured, commonly used and machine-readable format. However, this right doesnot apply where it would adversely affect the rights and freedoms ofothers.
8.11 If you consider that our processing of yourpersonal information infringes data protection laws, you have a legal right tolodge a complaint with a supervisory authority responsible for data protection.You may do so in the EU member state of your habitual residence, your place ofwork or the place of the alleged infringement.
8.12 To the extent that the legal basis for ourprocessing of your personal information is consent, you have the right towithdraw that consent at any time. Withdrawal will not affect the lawfulness ofprocessing before the withdrawal.
8.13 You may exercise any of your rights inrelation to your personal data by written notice to us in addition to the othermethods specified in this Section 8.
9.0 About cookies
9.1 A cookie is a file containing an identifier(a string of letters and numbers) that is sent by a web server to a web browserand is stored by the browser. The identifier is then sent back to the servereach time the browser requests a page from the server.
9.2 Cookies may be either “persistent” cookies or“session” cookies: a persistent cookie will be stored by a web browser and willremain valid until its set expiry date, unless deleted by the user before theexpiry date; a session cookie, on the other hand, will expire at the end of theuser session, when the web browser is closed.
9.3 Cookies do not typically contain any informationthat personally identifies a user, but personal information that we store aboutyou may be linked to the information stored in and obtained fromcookies.
10.0 Cookies that weuse
10.1 We use cookies for the followingpurposes:
(a) authentication – we do not use cookies toidentify you when you visit our website and as you navigate ourwebsite;
(b) status – we do not use cookies to help us todetermine if you are logged into our website;
(c) personalization – we do not use cookies tostore information about your preferences and to personalise the website foryou;
(d) Security – we use cookies asan element of the security measures used to protect user accounts, includingpreventing fraudulent use of login credentials, and to protect our website andservices generally;
(e) advertising – we do not use cookies to helpus to display advertisements that will be relevant to you;
(f) analysis – we do use cookies to help us toanalyse the use and performance of our website and services;
(g) cookie consent – we use cookies to store yourpreferences in relation to the use of cookies moregenerally.
11.0Cookies used by ourservice providers
11.1 Our service providers use cookies and thosecookies may be stored on your computer when you visit our website.
11.2 We use Google Analytics to analyse the useof our website. Google Analytics gathers information about website use by meansof cookies. The information gathered relating to our website is used to createreports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.
11.3 We do not publish Google AdSense advertisementson our website. To determine your interests, Google will track your behaviouron our website and on other websites across the web using cookies. Thisbehaviour tracking allows Google to tailor the advertisements that you see onother websites to reflect your interests (but we do not publish interest-basedadvertisements on our website).] You can view, delete or add interestcategories associated with your browser by visiting: https://adssettings.google.com.You can also opt out of the AdSense partner network cookie using those settingsor using the Network Advertising Initiative’s multi-cookie opt-out mechanismat: https://optout.networkadvertising.org.However, these opt-out mechanisms themselves use cookies, and if you clear thecookies from your browser your opt-out will not be maintained. To ensure thatan opt-out is maintained in respect of a particular browser, you may wish toconsider using the Google browser plug-ins available at: https://support.google.com/ads/answer/7395996.
12.0Managing cookies
12.1 Most browsers allow you to refuse to acceptcookies and to delete cookies. The methods for doing so vary from browser tobrowser, and from version to version. You can however obtain up-to-dateinformation about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en(Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences(Firefox);
(c) https://www.opera.com/help/tutorials/security/cookies/(Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies(Internet Explorer);
(e) https://support.apple.com/kb/PH21411(Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy(Edge).
12.2 Blocking all cookies will have a negativeimpact upon the usability of many websites.
12.3 Ifyou block cookies, you will not be able to use all the features on ourwebsite.
13.0 Our details
13.1 This website is owned and operated byLucavi
13.2 We are registered in England and Wales underregistration number 13356494 , and our registered office is at; 10-12 MulberryGreen, Harlow, Essex, United Kingdom, CM17 0ET
13.3 Our principal place of business is at LucaviLtd, PO Box 13149, HARLOW, CM20 9TS
13.4 You can contact us:
(a) by post, to the postal address givenabove;
(b) using our website contact form;
(c) by telephone, on the contact number publishedon our website from time to time; or
(d) by email, using the email address publishedon our website from time to time.
14.0 Data protection officer
14.1 Ourdata protection officer’s contact details are: sales@Lucavi.co.uk
