Privacy Policy
Privacy Notice
Effective Date: 14 October 2024
Last Updated: 14 October 2024
Welcome to Luxuries Unlocked. This Privacy Notice outlines how Adver Tech Global Ltd ("we," "our," or "us") collects, uses, stores, and protects your personal information. We are committed to safeguarding your privacy and ensuring your personal data is handled securely and transparently. This policy complies with the UK Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR).
1. Company Details
Company Name: Adver Tech Global Ltd
Company Number: 15937555
Registered Office Address: 128 City Road, London, United Kingdom, EC1V 2NX
2. Introduction
This Privacy Notice informs you about how we collect and process information from or about you when you use our competitions platform and engage with our marketing activities across various channels, including SMS, email, social media, and our website. It covers both personal and non-personal information and explains your rights and our obligations under the law.
We are committed to protecting your privacy and the confidentiality of your personal information. Our policy is not just an exercise in complying with the law but a continuation of our respect for you and your personal information.
3. Data Protection Officer (DPO)
We have appointed a Data Protection Officer responsible for overseeing our data protection strategy and its implementation to ensure compliance with UK GDPR requirements.
Contact Information:
Name: Paul Somerville
Support: Contact via Luxuries Unlocked Facebook Page.
If you have any questions or wish to exercise your data protection rights, please contact our DPO.
4. Data We Process
We collect, use, store, and transfer various types of personal data about you, categorized as follows:
Identity Data: First name, last name, title, date of birth, and other identifiers.
Contact Information: Billing address, delivery address, email address, telephone numbers.
Transaction Data: Payment details, purchase history, product and service details.
Technical Data: IP address, browser type and version, device information, operating system, and platform.
Profile Data: Username, password, interests, preferences, feedback, survey responses.
Marketing Data: Preferences for receiving marketing communications, communication preferences, responses to marketing activities.
Aggregated Data: Statistical or demographic data that does not identify you personally.
Aggregated Data
Aggregated data is data that does not identify you as an individual. It may be derived from your personal data but does not reveal your identity.
Example: We may aggregate profile data to assess interest in a product or service.
Note: If we combine aggregated data with your personal information so that it can identify you, we treat the combined data as personal information and use it in accordance with this Privacy Notice.
5. Special Categories of Personal Data
We do not collect any special categories of personal data, such as data concerning your race, religion, health, or biometric information.
6. Lawful Bases for Processing Your Personal Data
We process your personal data based on the following lawful bases:
Contractual Necessity: To fulfill our contractual obligations with you.
Consent: When you have given explicit consent for specific processing activities, particularly for marketing communications.
Legitimate Interests: For purposes such as business administration, fraud prevention, and improving our services.
Legal Obligations: To comply with legal requirements, such as tax laws and reporting obligations.
If our lawful basis for processing your data changes, we will notify you accordingly.
7. Information We Process Due to Our Contractual Relationship
When you create an account, purchase products or services, or agree to our terms and conditions, a contract is formed between us. We process your information to:
Verify your identity for security purposes.
Sell products and provide services to you.
Offer personalized suggestions and advice.
Enhance your user experience on our platform.
We will continue processing your data until the contractual relationship ends.
8. Information We Process With Your Consent
We obtain your consent to process your data for marketing purposes. This includes:
Sending promotional emails and SMS messages.
Engaging with you on social media platforms.
Utilizing cookies and tracking technologies to personalize your experience.
You can withdraw your consent at any time by contacting our support. However, withdrawing consent may limit your ability to use certain features of our website or services.
9. Information We Process for Legitimate Interests
We may process your data based on our legitimate interests, which include:
Enhancing our business operations and customer service.
Preventing fraud and ensuring the security of our platform.
Protecting our legal rights and interests.
We ensure that our legitimate interests are balanced against your rights and freedoms.
10. Information We Process Due to Legal Obligations
We may process your personal data to comply with legal obligations, such as:
Responding to law enforcement requests.
Fulfilling regulatory requirements.
Ensuring compliance with tax laws.
11. Specific Uses of Information
11.1 Information Shared with Third Parties
When you post information on our website (e.g., forum messages, tagged images), it may be accessible to other users and third parties. We reserve the right to use this information as we deem appropriate. However, we do not control how third parties may use your publicly shared information.
You can request the deletion of your posted personal information by contacting our support, subject to legal requirements.
11.2 Complaints Regarding Content
We moderate user-generated content but cannot guarantee immediate removal of inappropriate content. If you have a complaint about content on our website, we will investigate and may remove the content if justified or legally required.
11.3 Payment Information
We do not store or process your payment information directly. All payment transactions are handled securely by third-party providers such as Stripe. These providers are responsible for the security of your payment data.
11.4 Direct Debit Information
If you set up a direct debit, your information is processed by our bank in accordance with our instructions. We do not retain a copy of your direct debit details and are registered under the Direct Debit Guarantee Scheme.
11.5 Job Applications and Employment
Information provided during job applications is retained for up to three years for future opportunities. Employment-related data is kept for the duration of employment and up to six years post-employment.
11.6 Communicating with Us
When you contact us, we retain your personal data to respond to your inquiries and improve our services.
11.7 Complaints Handling
We record and use your information to address and resolve complaints effectively. In some cases, we may share your information with third parties to resolve the issue.
11.8 Affiliate and Business Partner Information
Data provided by affiliates and business partners is used solely for tracking referrals and managing commissions. We maintain confidentiality and expect partners to adhere to similar privacy standards.
12. Use of Automated Systems and Tracking Technologies
12.1 Cookies
We use cookies and similar technologies to enhance your experience, analyze website usage, and support our marketing efforts. These include:
Essential Cookies: Necessary for website functionality.
Performance Cookies: Collect data on website performance and usage.
Functional Cookies: Remember your preferences and settings.
Marketing Cookies: Track your behavior to deliver personalized ads.
Managing Cookies: You can manage your cookie preferences through your browser settings. For more details, refer to our Cookie Policy.
12.2 Personal Identifiers from Browsing Activity
We collect data such as IP address, browser type, device information, and browsing patterns to improve our services and personalize your experience. This information may be combined with other data to identify you personally if you have an account on our platform.
12.3 Re-marketing
We may use re-marketing techniques to display ads for our products or services on other websites you visit. This involves placing cookies on your device to track your browsing behavior. You can opt-out of re-marketing by adjusting your cookie settings or using opt-out tools provided by advertising partners.
13. Disclosure and Sharing of Your Information
13.1 Information from Third Parties
We may receive data indirectly from third parties, which does not personally identify you. This information is used to enhance our services and improve user experience.
13.2 Third-Party Advertising
Third-party advertisers on our website may use cookies and other technologies to collect information about your visits and interactions with our site. We do not control these third-party practices, and this Privacy Notice does not cover their data handling.
13.3 Credit Reference
To combat fraud, we may share information with credit reference agencies if a client cancels payment without providing a valid reason, allowing us to pursue refunds.
13.4 Data Processing Outside the UK
We may transfer your data to countries outside the UK, including within our corporate group or to trusted service providers that comply with UK GDPR standards. Appropriate safeguards are in place to protect your data during such transfers, including:
Processing by entities within the same corporate group adhering to the same data protection rules.
Data protection clauses in contracts with processors, approved by UK supervisory authorities.
Compliance with approved codes of conduct or certification mechanisms.
Agreements with public authorities ensuring data protection.
14. Control Over Your Information
14.1 Updating Your Information
Please ensure that your personal data is accurate and up-to-date. You can update your information by logging into your account on our website or contacting us directly.
14.2 Accessing Your Information
You have the right to request access to the personal data we hold about you. To obtain a copy of your data, contact our support. We will respond within the required timeframe and may charge a reasonable fee for processing your request.
14.3 Removing Your Information
You can request the deletion of your personal data by contacting us. Please note that removing your data may limit our ability to provide certain services to you.
14.4 Verifying Your Information
To protect your privacy, we may require verification of your identity before processing requests to access, edit, or delete your personal data.
15. Other Important Information
15.1 Use of Site by Children
Our services are not intended for individuals under 18 years of age. We do not knowingly collect personal data from children. If you are under 18, please do not use our website or services.
15.2 Encryption of Data
We use Secure Sockets Layer (SSL) technology to encrypt data transmitted between your browser and our servers. Look for the closed padlock symbol in your browser’s URL bar to ensure your connection is secure.
15.3 How to Complain
If you are dissatisfied with our Privacy Policy or how we handle your personal data, please contact us first to resolve the issue.
Complaint Handling Procedure: Our Terms and Conditions
If unresolved, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at https://ico.org.uk/make-a-complaint/.
16. Retention of Personal Data
We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Notice, unless a longer retention period is required or permitted by law. Typical retention periods include:
Service Provision: Duration of your account or as needed to provide services.
Legal Compliance: Duration required by law, such as tax regulations.
Dispute Resolution: Duration necessary to support claims or defences in legal proceedings.
Specific retention periods:
Job Applications: Up to three years for future opportunities.
Employment Data: Duration of employment plus six years post-employment.
17. Compliance with the Law
Our Privacy Policy is designed to comply with the data protection laws of all jurisdictions in which we operate. If you believe our policy does not comply with the laws of your jurisdiction, please contact us to discuss your concerns.
However, ultimately it is your choice whether you wish to use our website.
18. Review of This Privacy Policy
We may update this Privacy Notice periodically to reflect changes in our practices or legal requirements. The most current version will always be available on our website. We encourage you to review this policy regularly to stay informed about how we protect your personal data.
Contact Us
If you have any questions or concerns about this Privacy Notice or our data practices, please contact our Data Protection Officer:
Address: 128 City Road, London, United Kingdom, EC1V 2NX
We are committed to addressing your concerns and ensuring your privacy is respected.
Acknowledgment
By using our website and services, you acknowledge that you have read and understood this Privacy Notice and agree to our collection, use, and sharing of your personal data as described herein.