Privacy Notice – LUUX Digital Media Ltd
1. Introduction
Welcome to LUUX Digital Media Ltd’s privacy notice. LUUX Media Ltd (company number 13179748 and whose registered office is at 15 Whiting Street, Bury St Edmunds, Suffolk, England IP33 1NX), (“LUUX Digital Media”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal data.
Luux Digital Media is a media agency which works with luxury brands and high net worth individuals.
When Luux Media provides services on behalf of our clients, for example, when we collect data for them via forms and surveys, we act as a “processor” on behalf of our clients, who are the data controller in relation to the processing of any personal information processed as part of the services.
Please note that this privacy notice relates to our processing of any personal information about you for our own purposes where we act as a data “controller”, for example when we collect, use and share personal information if you use our website, register or attend an event organised or hosted by us, apply for a job with us, or where we interact with you in relation to the provision of our services and the operation of our business. This privacy notice aims to give you information on how LUUX Digital Media collects and processes your personal data. This website is not intended for children and we do not knowingly collect data relating to children.
2. Contact details
If you have any questions about this privacy notice or our privacy practices, please contact ourdata privacy manager in the following ways:
Email address: hello@luux-media.com
Postal address: 16 Ongar Road, London SW6 1SJ
3. Third-party links
This 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 notice of every website you visit.
4. The data we collect about you
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes first names, last name and title.
• Contact Data includes postal address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• 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 interests, preferences (including inferences about them), feedback and survey responses.
• Usage Data includes information about how you use our website, products and services and those of third parties (including our clients and other companies with whom we have partnered).
• Marketing and Communications Data includes your preferences in receiving marketing from us, our clients and/or other third parties with whom we have partnered.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. 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 notice.
5. 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, 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 the services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
6. How is your personal data collected?
We use different methods to collect data from and about you including through:
• Data provided directly by you. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise.
• Automated technologies or interactions. As you interact with our website, we will 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. Please see the cookie section below for further details.
• Data collected and/or generated through our interactions with you. We may collect and/or generate certain data about you as part of our interactions with you. In particular, we may create Profile Data which consists of inferences regarding your interests and preferences this way.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources including analytics providers, social media platforms, search engines, data brokers and other publicly available sources such as such as Companies House and the Electoral Register.
7. How we use your personal data
We will only use your personal data when we have a lawful basis to do so. 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 (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 obligation.
• Where we have your consent, for example, before sending third party direct marketing communications to you. You have the right to withdraw consent at any time by contacting us.
8. Purposes for which we will use your personal data
We may process your personal information for the following purposes:
• to provide you with the information, products and services you have requested and send you marketing and advertising materials or to process your job application;
• for system administration purposes and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to monitor your use of our website and the websites of our clients (and others with whom we have partnered) to improve the user experience and to ensure that content is presented in the most effective manner for you and for your device;
• to provide customer support and ensure we provide a good level of customer service;
• to tailor any marketing or advertising on other websites and social media platforms so that it is more relevant to you;
• to notify you of any changes to our services;
• to conduct marketing analysis to allow us to assess trends (including using your personal information to evaluate, analyse or predict certain personal aspects relating to you, such as your preferences, economic situation, interests, and/or location);
• to create “audiences” for the purposes of personal advertising made up of other individuals who share similar characteristics with you and whose interests, attributes and/or preference we can therefore infer;
• for security and fraud prevention;
• to ensure that our website is safe and secure; and
• to comply with applicable laws and regulations.
We may also match personal information that you provide to us directly with other information about you obtained from or held by third party sources (such as social media platforms). This may include your contact details, demographic data, your social media interactions, preferences, shopping habits, interests, geographic location and age or age range. We may use this personal information to tailor and show advertisements more relevant to you either on our website or on third party websites (including social media platforms).
9. Cookies
When you visit our website, we may also collect information from you automatically, for example using cookies and other similar technologies as described above. A cookie is a small file of letters and numbers that we may set on your device.
This type of information may include the following:
• information about your device, operating system and IP address;
• browser type and version; and
• information about your visit on our website, our client’s website and the websites of third parties with whom we have partnered, including URL, clickstream (i.e. your journey to, through and from the site), length of visits to certain pages, and page interaction information.
The cookies we use fall into the following categories:
• Session cookies: These allow our site to link your actions during a particular browser session. These expire each time you close your browser and do not remain on your device afterwards.
• Persistent cookies: These are stored on your device in between browser sessions. They allow your preferences or actions across the site to be remembered. These will remain on your device until they expire, or you delete them from your cache.
• Strictly necessary cookies: These cookies are essential for you to be able to navigate the site and use its features. Without these cookies, the services you have asked for could not be provided.
• Performance cookies: These cookies collect information about how you use the site, e.g. which pages you go to most often.
• Functionality cookies: These cookies allow the site to remember the choices you make (such as your user name, language, last action and search preferences) and provide enhanced, more personal features.
If you do not wish for cookies to be installed on your device, you can change the settings on your browser or device to reject cookies. For more information about how to reject cookies using your internet browser settings please consult the “Help” section of your internet browser (or alternatively visit http://www.aboutcookies.org). Please note that, if you do set your Internet browser to reject cookies or otherwise withdraw your consent in relation to cookies, you may not be able to access all of the functions of the site.
10. Disclosures of your personal data
We may share your personal information with our suppliers, business partners and service providers, where they are helping us to market and advertise our services as well as providing our services to you.
We may disclose your personal information to other third parties in the following cases:
• for the purposes of research, evaluation, and analysis;
• in the event that we sell any business or assets, in which case we may disclose your personal information to the prospective buyer of such business or assets
• if we or substantially all of our assets are acquired by a third party, in which case personal information held by us about our customers and visitors to our websites will be one of the transferred assets;
• if we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligation or request; or
• to protect the rights, property or safety of us or our users, or others, and in order to enforce or apply our terms and conditions (this includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
11. International transfers
The personal information that we collect may be transferred to, and stored at, a destination outside the EEA or the UK, including countries, which have less strict, or no data protection laws, when compared to those in the EEA or the UK. Whenever we transfer your information in this way, we will take steps which are reasonably necessary to ensure that adequate safeguards are in place to protect your personal information and to make sure it is treated securely and in accordance with this privacy notice. In these cases, we rely on approved data transfer mechanisms (such as standard contractual clauses) to ensure your information is subject to adequate safeguards in the recipient country. If you are located in the UK or the EEA, you may contact us for a copy of the safeguards which we have put in place to protect your personal information and privacy rights in these circumstances.
12. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
13. Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity and Financial Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
14. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. There are rights to:
• request access to your personal data;
• request correction of your personal data;
• request erasure of your personal data;
• object to processing of your personal data;
• request restriction of processing your personal data;
• request transfer of your personal data; and
• withdraw consent.
You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
If you wish to exercise any of the rights set out above, please contact us using the contact details found at the top of this privacy notice.
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 certain circumstances and in accordance with the law.
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.
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.
15. Changes to the privacy notice and your duty to inform us of changes
We keep our privacy notice under regular review. This version was last updated in January 2022.
