Effective Date: 1st May, 2022
We are LUXIS BALTIC OÜ (“Luxclusif”, “we”, “us”, “our”), and we are committed to protecting your privacy.
Luxclusif is the controller for the purposes of the General Data Protection Regulation (the “GDPR”) a company registered in Estonia (Company No. 12824968), with its registered office located at Harju maakond, Jõelähtme vald, Loo alevik, Aasa tee 1, 74201 Estonia, and manages luxclusif.com (the “website”).
2. WHAT INFORMATION DO WE COLLECT, AND HOW?
When you interact with us, whether by using our Website or communicating with us, we may collect the following information about you:
- Information you give us: you may give us information about yourself if you sign up for an account on our Website, complete any online forms (such as registration or request forms), opt in to receive our newsletters and special offers, or correspond with us (by email, telephone, social media or otherwise).
Depending on what you provide, this information can include your name and contact details such as phone number and email address. We may also collect information from your company, such as identification, contacts, addresses and tax and financial information.
- Information we receive from other accounts or sources: we can receive information about you from other sources, such as from your other accounts or other websites, including social media providers like Instagram and LinkedIn, analytics partners, and payment service providers.
You can see more details about the third parties we use in section 5.
- Information our IT systems collect about you: each time you visit the Website, certain information will be created and automatically recorded by our IT systems. That information includes:
- Cookies: you can see more details about cookies in section 7, but these small text files can help improve your experience with the Website and make it easier to interact with us. This may include storing your location or language preferences to save you having to re-enter information when returning to.;
- Device information: the information provided by your device will differ depending on which type of device you are using (whether it’s a PC, Mac, iPhone, Android, or otherwise) and the settings on that device, but includes the type of device you have, the device’s IP address, the browser you are using, your mobile network provider (for mobile devices), the pages you have visited, your time zone and country location, and crash or download error reports.
3. WHAT DO YOU USE MY INFORMATION FOR?
To provide you services and the Website, including to administer your account and to optimize your experience we need to use the information that we collect in a number of different ways.
Please scroll down to find out the detailed purposes for which we collect your information, and what specific information is collected:
- To register and manage your account in our Website, we may collect from your company but also from you, such as your name, email, password and other additional details you may wish to add in your account, like phone number.
- To fulfill the orders you make through our website, we collect information from your company, and phone number.
- To collect payment from you we collect your payment information, which comprises the credit/debit card’s number, holder’s name and CCV – we do not store them and only transfer them to our authorized payment providers.
- To provide you with support services (including helping you to solve any issue you have with our services,) we collect your name, email, password and addresses and your contact history with us.
- To administer, maintain and optimize our Website and our services, we collect your device information (such as your device IP address and device type), Cookie identifiers and browsing information.
- To perform fraud and credit checks and if we can do business with you, we collect your name; your company details, purchase history and device information (such as IP address and device type.
- To send you marketing communications, we collect your Name and Email.
4. WHO DO YOU SHARE MY INFORMATION WITH?
To provide the Website and our services, we work with a number of carefully selected third parties. To do this, we may share your information with these third parties in the following limited circumstances:
- Third party service providers for business purposes: to function properly, we rely on a number of carefully selected third parties to provide us with services and products. We permit these companies to use your personal information only to the extent necessary to provide us with their services and products. Below you can find the types of third parties we use:
- Payment providers that we use to process your financial information (including your credit/debit card details or bank details) so that we can collect payment from you.
- Anti-fraud and credit check providers to keep us and you secure. They have access to and process your information and associated orders in order to check for any fraudulent behavior.
- Analytics and search engine providers, like Google, that we use to assist us in the improvement and optimization of the Website. These providers are based in the United States .
- Marketing Tools providers that help us to enable our marketing. These providers are based in the Unites States.
- IT/technology providers that we use to support, maintain and provide our technology and IT infrastructure that supports our Website and the storage of your information. This includes Google and Microsoft Azure that we use to host your information, based on Singapore and Europe.
- to comply with legal requests: on occasion we may be required to liaise with various regulators and law enforcement agencies in a number of different countries, whether as a result of law, a court order, or another legal process. Although we dispute requests wherever suitable, in some cases we may have to share your information with the regulators or law enforcement agencies. Where we consider it appropriate, and provided we are not prohibited from doing so by law or court order, we will attempt to notify you of these legal demands; and
- Aggregated information with third parties: we may aggregate your information with the information of other customers, creating a dataset of information about the usage of our Website, purchase of products, and other general, grouped information about our customers on the basis of our legitimate interest to understand the usage of our services. Although this dataset is aggregated and anonymized, meaning it cannot identify you as an individual, it provides a valuable insight into the use of our Website and we may therefore share it with select third parties. These parties may include providers of plugins or similar technologies to help measure traffic, our partners and other providers to allow them to better stock products, and our investors.
5. TRANSFERS OF YOUR PERSONAL DATA
To provide our Website and our services, in accordance with the purposes set out above, we may transfer and store the personal information that we collect from you to a destination inside or outside of the United States, mostly from and to the European Economic Area (“EEA”).
When transferring personal information to one of our third party services’ providers set out above, we rely on different adequacy and security measures to ensure we comply with the relevant privacy regulations.
We use technology such as "cookies" to collect information and store your online preferences. Cookies are small pieces of information sent by a web server to a web browser, which allows the server to uniquely identify the browser on each page.
We use the following categories of cookies on our Website:
NECESSARY COOKIES These cookies are essential in order to enable you to move around the website and use its features. Without these cookies, services you have asked for such as remembering your login details cannot be provided.
ANALYTICAL COOKIES These cookies collect anonymous information on how you use our Website. For example, we use Google Analytics cookies to help us understand how customers arrive at our site, browse or use our site and highlight areas where we can improve areas such as navigation. The data stored by these cookies does not show personal details from which your individual identity can be established.
If you want to delete any cookies that are already on your computer, please refer to the help and support area on your Internet browser for instructions on how to locate the file or directory that stores cookies. Information on deleting or controlling cookies is available at www.AboutCookies.org. Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our Website.
You can withdraw your consent to these cookies at any time through the following options:
- Google Analytics cookies across all websites, please visit Google Analytics Opt-out Browser Add-on;
- other third party cookies relating to behavioral advertising, please go to www.aboutads.info.
- any other type of cookies, you can clean the cookies through your browser settings.
Please note that refusing cookies does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted out will no longer deliver advertisements tailored to your web preferences and usage patterns, so you may see a greater number of advertisements that are irrelevant to you and your preferences.
Many web browsers support Do Not Track technology. While we strive to offer you choices when you use our website and services, we do not promise that we will be able to receive or honor web browser Do Not Track signals.
Keeping you and your personal information secure is very important to us. We take a number of reasonable steps to try to protect the personal information that you provide, including:
- using a Secure Socket Layer (“SSL”) to encrypt the personal data that you send us during the order process (including any financial information such as credit or debit card details); requiring you to establish a password to access your account on our Website;
- not keeping details of your credit or debit card that would enable any third party to transact using that credit or debit card (such as your CCV number); and
- regularly monitoring our servers and IT systems for possible vulnerabilities and attacks. Unfortunately, despite this, the transmission of information via the Internet is not completely secure. We cannot guarantee the security of your personal data transmitted to or through our Website, and any such transmission is at your own risk. In particular, please keep in mind that if you voluntarily disclose personal information through other means of communication than the Website in a non-protected environment (such as through email, sms, online messages) then that information can be collected and used by others outside of our or your control.
8. HOW LONG WILL YOU USE MY INFORMATION FOR?
We retain the data you provide to us for as long as you have your account with us and thereafter for such period as you may have questions or a claim in relation to our services, notwithstanding any superior retention period that we may be obliged to observe in accordance with legal requirements applicable to us.
In some circumstances you can ask us to delete your data as set out below.
9. WHAT ARE MY PRIVACY RIGHTS?
You have certain rights in relation to the personal data we hold about you depending on local law. Some of these only apply in certain circumstances. Please note that we may require you to verify your identity before responding to any requests to exercise your rights and that can include asking a set of security questions to ensure it is you. When you have appointed someone else to do the request on your behalf, that person and/or organization needs to show a valid power of attorney issued by you.
If you are located within the EEA, the following rights apply to you:
- Access. You have the right to know whether we process personal data about you, and if we do, to access data we hold about you and certain information about how we use it and who we share it with (including the categories of personal data we share with businesses for their direct marketing uses and the names and addresses of those businesses). Please note that in “My Account” dashboards, you can see information about your company and you, namely your account details (such as name, email, phone number), the addresses you use for billing and shipping and your order history.
You can also request a copy of your information. If you require more than one copy of the data we hold about you, we may charge a reasonable administration fee.
We may not provide you with certain personal data if providing it would interfere with another’s rights (e.g. where providing the personal data we hold about you would reveal information about another person) or where another exemption applies.
- Portability. You have the right to receive a subset of the personal data we collect from you in a structured, commonly used and machine-readable format and a right to request that we transfer such personal data to another party. The relevant subset of personal data is data that you provide us with your consent or for the purposes of performing our contract with you. If you wish for us to transfer the personal data to another party, please ensure you detail that party and note that we can only do so where it is technically feasible. We are not responsible for the security of the personal data or its processing once received by the third party. We also may not provide you with certain data if providing it would interfere with another’s rights (e.g. where providing the personal data we hold about you would reveal information about another person or our trade secrets or intellectual property).
- Correction. You have the right to correct any personal data held about you that is inaccurate. You can edit your information in “My Account” settings. You can also request the correction by emailing us. Please note that in some cases we can ask you to explain in detail why you believe the personal data we hold about you to be inaccurate or incomplete so that we can assess whether a correction is required. Please note that whilst we assess whether the personal data we hold about you is inaccurate or incomplete, you may exercise your right to restrict our processing of the applicable data as described below.
- Erasure. You may request that we erase the personal data we hold about you in the certain circumstances. Please scroll down to know what those are:
- you believe that it is no longer necessary for us to hold the personal data we hold about you;
- we are processing the personal data we hold about you on the basis of your consent, and you wish to withdraw your consent and there is no other ground under which we can process the personal data;
- we are processing the personal data we hold about you on the basis of our legitimate interest and you object to such processing. Please provide us with detail as to your reasoning so that we can assess whether there is an overriding interest for us to retain such personal data;
- you no longer wish us to use the personal data we hold about you in order to send you promotions and special offers;
- you believe the personal data we hold about you is being unlawfully processed by us.
Also note that you may exercise your right to restrict our processing the data whilst we consider your request as described below.
Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure. Please note, however, that we may retain the personal data if there are valid grounds under law for us to do so (e.g., for the defense of legal claims or freedom of expression) but we will let you know if that is the case.
Where you have requested that we erase data that we have made public and there are grounds for erasure, we will use reasonable steps try to tell others that are displaying the data or providing links to the data to erase the data too.
• Restriction of Processing to Storage Only. You have a right to require us to stop processing the personal data we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal data, we may use it again if there are valid grounds under data protection law for us to do so (e.g. for the defense of legal claims or for another’s protection).
Please scroll down to know the cases where you may request we stop processing and just store the personal data we hold about you.you believe the personal data is not accurate for the period it takes for us to verify your claim;
- we wish to erase the personal data as the processing we are doing is unlawful but you want us to retain the personal data for storage but not further process it;
- we wish to erase the personal data as it is no longer necessary for our purposes but you require it to be stored for the establishment, exercise or defense of legal claims; or
- you have objected to us processing personal data we hold about you on the basis of our legitimate interest and you wish us to stop processing the personal data whilst we determine whether there is an overriding interest in us retaining such personal data.
You also have the right to object to our processing of data about you and we will consider your request if we are processing the data we hold about you (including where the processing is profiling) on the basis of our or a third party’s legitimate interest and you object to such processing. Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process it in relation to legal claims. Also note that you may exercise your right to request that we stop processing the data whilst we make the assessment on an overriding interest;
• Withdrawal of Consent: You can withdraw your consent at any time by unsubscribing at the bottom of each email received or by writing emailing us as set out below.
To exercise or to know more about these rights, please contact us at email@example.com. We must respond to a request by you to exercise those rights without undue delay and at least within one month (although this may be extended by a further two months in certain circumstances).
Depending on the country you live or work, you may have the right to file a complaint with the competent supervisory authority.
11. UPDATES TO THIS POLICY