Privacy and cookies policy
Lavish Lockets (“us,” or “we”) has created this Privacy Statement to inform you about how we collect, use and disclose information.
This Privacy Statement applies to information collected through this website and any mobile sites, applications, widgets, and other interactive features that link to this Privacy Statement.
Lavish Lockets grants independent consultants selling rights to its products (hereinafter referred to as Lavish Consultants).
Lavish Consultants are not employed by Lavish Lockets. Therefore, Lavish Lockets does not control, and is not responsible or liable for the collection, use or disclosure of Personal Information by Lavish Consultants, including for their marketing purposes. If you provide information to a Lavish Consultant which is processed through the Site, Lavish Lockets will have access to it and shall treat it in accordance with this Privacy Statement. Lavish Consultants may provide Lavish Lockets with information regarding their customers, in which case Lavish Lockets will treat such information, once in its possession, in accordance with this Statement.
If you are the customer of a Lavish Consultant, you should check with your Representative directly to learn about her data privacy practices.
If you apply to become or are a Lavish Consultant, in addition to the generally applicable provisions of this Privacy Statement, please review the Independent Sales Representative section at the bottom of this Privacy Statement to see important information about additional privacy practices that apply to you
- This Policy sets out the obligations of Lavish Lockets, regarding data protection and the rights of Customers, business contacts and independent consultants in respect of their personal data under EU Regulation 2016/679 General Data Protection Regulation (“GDPR”).
- In this policy, “we”, “us” and “our” refer to Lavish Lockets.
- The GDPR defines “personal data” as any information relating to an identified or identifiable natural person, an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
- This Policy sets our obligations regarding the collection, processing, transfer, storage, and disposal of personal data. The procedures and principles set out herein must be followed at all times
- We are committed to safeguarding the privacy of our website visitors and service users.
How we use your personal data
- In this Section we have set out the general categories of personal data that we may process;
- in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
- the purposes for which we may process personal data; and
- the legal bases of the processing.
- 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.
- 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 and email address. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services.
- 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 be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions
- 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 – subject to you consent.
- 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.
- 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.
- Please do not supply any other person’s personal data to us.
Providing your personal data to others
- 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.
- We will not disclose your personal data to any third party supplier unless in direct connection with your order.
- 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.
Retaining and deleting personal data
We retain personal data only for as long as necessary to provide the Services you have requested and thereafter for a variety of legitimate legal or business purposes. These might include retention periods:
- mandated by law, contract or similar obligations applicable to our business operations;
- for preserving, resolving, defending or enforcing our legal/contractual rights; or
- needed to maintain adequate and accurate business and financial records.
When personal data is no longer required, all reasonable steps will be taken to erase or otherwise dispose of it without delay
Security of personal data
- We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
- We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
- Personal data will be handled with care at all times and will not be left unattended or on view to unauthorised parties at any time
- The following personal data will be stored by us in encrypted form: your password(s).
- Data that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.
- You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
- You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website).
- We may update this policy from time to time by publishing a new version on our website.
- You should check this page occasionally to ensure you are happy with any changes to this policy.
- We may notify you of changes to this policy by email.
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 in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
Your principal rights under data protection law are:
- the right to access- You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data.
- the right to rectification- You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
- the right to erasure (also known as the right to be forgotten)– In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
- the right to restrict processing- In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
- the right to object to processing- You have the right to object to our processing of your personal data on grounds relating to your particular situation, If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose. You also have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest
- the right to data portability- Where consent has been given to process your personal data, you do have the right, under the GDPR, to receive a copy of your personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
- the right to complain to a supervisory authority– If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection.
- the right to withdraw consent– To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
You may exercise any of your rights in relation to your personal data by email or written notice.
Third party websites
- Our website may include hyperlinks to, and details of, third party websites.
- We have no control over, and are not responsible for, the privacy policies and practices of third parties.
Please let us know if the personal information that we hold about you needs to be corrected or updated.
- A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
- Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
- Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
- Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
- Blocking all cookies will have a negative impact upon the usability of many websites.
- If you block cookies, you will not be able to use all the features on our website.
Independent Sales Representatives
The following provisions are applicable only to Lavish independent consultants:
This Privacy Statement applies to the Personal Information of Lavish consultants collected by us , whether collected online or offline. This information would be collected in addition to any Personal Information we may collect from you as a Lavish lockets customer, as described above.
Once you are a Lavish Independent consultant, we may collect, use and disclose your Personal Information in accordance with this Privacy Statement, We may disclose your Personal Information:
- to managers and Team leaders, who may be independent Lavish Consultants;
- to current and potential customers who are seeking the assistance of a Lavish consultant; and
- as necessary to comply with legal requirements such as tax and record keeping obligations.