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Privacy Policy

1. Introduction

1.1 We are committed to safeguarding the privacy of our website visitors and customers; in this policy we explain how we will handle your personal data.

1.2 Our website incorporates privacy controls which affect how we will process your personal data. You have the option at any time to stop us from contacting you for marketing purposes. If you would like to change your marketing preferences, please email your request to help.uk@lumitylife.com.

1.3 We will not sell, resell, lease or license your personal information to any third parties.

2. How we use your personal data

2.1 In this Section 2 we have set out:

(a)   the general categories of personal data that we may process;

(b)   in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

(c)   the purposes for which we may process personal data; and

(d)   the legal basis of the processing.

2.2 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal bases for this processing are our legitimate interests, namely monitoring and improving our website and services.

2.3 We may process your account data ("account data"). The account data may include your name, email address, phone number, and delivery address. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent.

2.4 We may process your information included in your personal profile on our website ("profile data"). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is our legitimate interest, namely the proper administration of our website and business.

2.5 We may process information that you post for publication on our website or through our services ("publication data"). This publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent.

2.6 We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.

2.7 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details, your card details and the transaction details. We do not hold your card details nor do any company employees have access to your card details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal bases for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.

2.8 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent. We may in addition send out notifications to customers who have previously purchased similar goods or services from us. The legal basis for these communications is legitimate interest.

2.9 We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal bases for this processing are our legitimate interests, namely the proper administration of our website and business and communications with users.

2.10 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal bases for this processing are our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.11 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interest, namely the proper protection of our business against risks.

2.12 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

2.13 You should not supply any other person's personal data to us, unless we prompt you to do so.

3. Providing your personal data to others

3.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

3.3 In the event that you make a purchase on our website, we may disclose your personal data to review companies in order for them to collect feedback from you on our behalf. In this situation we hold a data processing agreement with the review company which strictly limits the way they can process your personal data.

3.4 We may disclose your personal data to our chosen suppliers or subcontractors so far as reasonably necessary for them to provide us with their services. These sub-contractors may be in technical service, payment and delivery services, advertising networks, analytics providers, search information providers, or credit reference agencies. We ensure that any contracts with these suppliers or subcontractors have appropriate safeguards in place to protect your data.

3.5 Financial transactions relating to our website and services are handled by our payment services providers; PayPal, Worldpay and Global Payments. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.

3.6 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4. International transfers of your personal data

4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

4.2 Our website is hosted by a subcontractor who processes data about European residents in Ireland. From Ireland they transfer data to the USA and Canada where they have data centres and cloud service providers. They support these through a variety of legal mechanisms approved by the European Commission, including the EU-U.S. Privacy Shield and European Commission decision 2002/2/EC.

4.3 Our customer service software is run by a subcontractor which is based in the USA. The European Commission has made an "adequacy decision" with respect to the data protection laws in the USA. The Company has certified its compliance with the EU-U.S. Privacy Shield frameworks with the U.S. Department of Commerce.

4.4 Our subscription customer orders are processed by a subcontractor which is based the USA. The European Commission has made an "adequacy decision" with respect to the data protection laws in the USA. Transfers to the USA will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.

4.5 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

5. Retaining and deleting personal data

5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

5.3 We will retain your personal data as follows:

(a) In general, we will store personal data you have provided to us for two years. If you are a subscription customer this 2-year period will only begin at the time of cancelation.

(b) If you delete information from your profile, it will be deleted from our current records, although it may not be deleted from any archives or backup copies we have;

(c) we will retain transaction data for 7 years.

5.4 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

6. Amendments

6.1 We may update this policy from time to time by publishing a new version on our website.

6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

6.3 We may notify you of changes to this policy by email.

7. Your rights

7.1 In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

7.2 Your principal rights under data protection law 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 supervisory authority; and

(h) the right to withdraw consent.

7.3 If you would like more information on these rights, please visit https://ico.org.uk/for-the-public/.

7.4 You may exercise any of your rights in relation to your personal data by emailing us at help.uk@lumitylife.com.

8. Cookies

Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a positive experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy.

9. You can contact us:

(a) by post, to:

Office 7, Floor 2

Tay House

300 Bath Street

Glasgow

G2 4JR

(b) by telephone, on +44 800 652 8678; or

(c) by email, using help.uk@lumitylife.com

10. Data Protection Manager:

10.1 Our data protection manager is James Kyle.

10.2 To get in touch please contact help.uk@lumitylife.com with your request.