PRIVACY POLICY
Last updated July 22, 2023
ACCURETTA SYSTEMS LIMITED (DOING BUSINESS AS “LUVANDER”. and its associated retail brand, Luvander, respect your concerns about privacy. This Privacy Policy (“Policy”) explains what personal information we collect through our Services (as defined below), how we use that information, to whom we disclose it, and how we safeguard personal information. Unless indicated otherwise, this Policy applies only to personal information collected from and about you through your use of the websites, microsites, mobile applications, and other online services of Luvander that expressly adopt, display, or link to this Policy, and then only to the extent indicated, and through your interaction with us offline, including when you visit or make a purchase at our physical retail stores in the United States (not including Puerto Rico and Canada) (collectively, the “Services”).
This describes how and why we might collect, store, use, and/or share (‘process‘) your information when you use our services (‘Services‘), such as when you:
- Visit our website at https://luvander.com, or any website of ours that links to this privacy notice
- Download and use our mobile application, our Facebook application, or any other application of ours that links to this privacy notice
- Engage with us in other related ways, including any sales, marketing, or events,etc
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at hello@luvander.com.
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.
Do we process any sensitive personal information? We do not process sensitive personal information.
Do we receive any information from third parties? We do receive any information from third parties.
How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.
In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.
How do you exercise your rights? The easiest way to exercise your rights is by visiting hello@luvander.com, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.
Want to learn more about what we do with any information we collect? Review the privacy notice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short:We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
When you visit our Services, you may provide us with certain personal information, such as your name, address, phone number, email address, personal preferences, payment card number, purchase and ordering information, demographic information, responses to survey questions, sizing information and any other information you choose to provide. Our Services may also give you the option to upload or share pictures or videos of yourself and others.
We collect this information at various places on our Services, such as when you check out with your online order; engage with our mobile applications; subscribe to catalogs, email offers, and mobile messaging offers; participate in surveys; enter contests or sweepstakes; or interact with special-event or program offers.
We may also collect information that you provide on our Services about people you know. For example, we collect your gift recipient’s contact information to process your gift orders. We may also collect contact information about your friends and family members when you participate in one of our refer-a-friend programs. In these instances, we may send a message to your friend or family member on your behalf (so please only submit email addresses of individuals with whom you have a personal or family relationship and who would want to receive the message from you).
Sensitive Information. We do not process sensitive information.
Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is stored by Stripe and Paypal. You may find their privacy notice link(s) here: https://stripe.com/privacy and https://www.paypal.com/myaccount/privacy/privacyhub.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short:Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
The information we collect includes:
- Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services(such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’), and hardware settings).
- Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
- Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.
Cookies, Clear Gifs and Similar Technologies
To better understand how you interact with our Services, we may collect information using cookies, clear-gifs (also known as web beacons or web bugs) and similar technologies.
A cookie is a small amount of data that’s stored by your browser on your device. It’s used to do things like see how you navigate our Services, what you click on, remember you and your online purchases when you return, and recognize you and honor a special deal for you, when you redeem one of our offers from a third party’s site. This helps us improve and deliver our Services, provide better customer service, tailor and improve your online experience, and tailor offers to you based on your unique tastes and a combination of your online and offline (e.g., in-store) interactions and purchase history.
A clear gif is a nearly invisible pixel-sized graphic image on a web page, web-based document or email message. It helps us do things like view the URL of the page on which the clear gif appears and the time the site, document or email in question is viewed; and recognize you and honor a special deal for you, when you navigate from a third party’s site to redeem one of our offers that may have appeared there. Clear gifs in emails help us confirm the receipt of, and response to, our emails, including those that you forward to friends and family; and they help deliver a more personalized or better online experience.
In addition to cookies and clear gifs, we may also use device identifiers, web storage, and other technologies to collect information about your interactions with our content and Services.
These technologies, illustrated above, may be used to help us see which of our interactive experiences online users like most. Cookies, clear gifs, and similar technologies also allow us to associate your online navigational information and purchases and interactions (both online and offline) with personal information you provide (such as name, address, phone number, survey responses, and email address). We associate this information to deliver products and services to you; improve our business; transact business; and market our products and services on this and other online services, and through a variety of media like email, mobile advertising, and direct mail.
Information collected when you use our Facebook application(s). We by default access your Facebook basic account information, including your name, email, gender, birthday, current city, and profile picture URL, as well as other information that you choose to make public. We may also request access to other permissions related to your account, such as friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission. For more information regarding Facebook permissions, refer to the Facebook Permissions Reference page.
Information Derived Through or Provided by Others
Affiliated entities, sister brands, vendors, social media networks, and advertising networks may provide us with, or supplement, information about you. We may use this information for a variety of operational or marketing purposes, such as to correct shipping information, market to you, deliver more relevant offers through customer insights, improve our business, and transact business.
Third-party apps, websites and services
If you use any third party apps, websites or services to access our services, your usage is subject to the relevant third party’s terms and conditions, cookies policy, and privacy policy. For example, if you interact with us on social media, your use is subject to the terms and conditions and privacy policies of the relevant social media platform (Facebook, Twitter etc.). The same applies if you use third party services, like Amazon’s Alexa. In certain cases we may be required to share your personal information, in relation to transactions and usage of the services, with the relevant third party.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
We use the personal information we obtain through the Services to:
- deliver our Services
- process your online orders;
- facilitate payment and transactions;
- create and manage your online account;
- personalize your online experience with content and offers that are tailored to your interests;
- provide customer service and respond to your inquiries and requests;
- include you in surveys and contests;
- enable you to post your content, such as comments, images or videos;
- facilitate networks of online social activity centered around our products and services;
- improve our Services, the manner in which offers are made on our Services, and the interactions and experience visitors have with our Services;
- enable you to interact with third-party content service providers, whether by linking to their sites, viewing their content within our online environment, or by viewing our content within their online environment;
- market our products and services that may be of interest to you; and
- create aggregated, pseudonymized or anonymized information for statistical purposes.
Third Party Analytics and Personalization Services
We may use third-party analytics and personalization services to analyze site metrics and performance, analyze our visitors’ preferences, and serve personalized content to you through the use some or all of the technologies described above, such as cookies and clear gifs.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
- Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
- Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
- Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e. express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e. implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
- If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
- For investigations and fraud detection and prevention
- For business transactions provided certain conditions are met
- If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
- For identifying injured, ill, or deceased persons and communicating with next of kin
- If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
- If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
- If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
- If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
- If the collection is solely for journalistic, artistic, or literary purposes
- If the information is publicly available and is specified by the regulations
In Short: We may share information in specific situations described in this section and/or with the following third parties.
We may need to share your personal information in the following situations:
We work with a number of trusted third parties to provide you high quality goods and services. Anybody we work with is subject to stringent security and data privacy assessments before we begin to do business with them and on an ongoing basis.
We always make efforts to anonymise data and only pass over personal information that is absolutely necessary for the purposes it is being processed. We always do so securely.
We have contracts in place with all suppliers that help us to ensure security and privacy of your personal information, these are reviewed and updated regularly and always in line with data protection laws.
- ACCURETTA SYSTEMS LIMITED –We will share your personal information, in certain circumstances with the other companies within the NEXT Group. This is so that we can provide personalised services across our Group.
- Delivery Partners –Helping us to deliver the goods you order to you including our brand partners that dispatch and deliver goods to you directly.
- IT Companies –Supporting us in maintaining our website and other business systems including; providing phone lines, data storage facilities, and providing and supporting Cloud based infrastructure used in providing our products and services.
- Marketing Companies and Online Advertising – Helping us to manage our electronic communications to you and to help us show you the advertising you are most likely to be interested in, companies that provide marketing and advertising assistance (including management of email marketing operations, mobile messaging services such as SMS, and services that deploy advertising on the internet or social media platforms, such as Facebook and Google) as well as analysis of the effectiveness of our advertising and communications campaigns.
- We use technologies such as cookies, pixels, and device IDs within digital marketing networks, ad exchanges and social media networks such as Facebook’s Custom Audience to get relevant marketing messages across to you.
- Consumer profiling organisations – These organisations provide demographic or other data to help better understand customers’ demographics, lifestyles or shopping.
- Payment processors – Payment card processors to process credit and debit card payments and store payment information.
- Credit Reference Agencies (CRAs) –We share your personal information with CRAs on an ongoing basis, including details of settled accounts and any debts not fully repaid on time. CRAs will share your information with other organisations.
The identities of the CRAs, and the ways in which they use and share personal information, are explained in more detail at:
– Experian Credit Reference Agency Information Notice
– TransUnion Credit Reference Agency Information Notice
– Equifax Credit Reference Agency Information Notice
We also take information from CRAs to allow us to make decisions about your credit account and credit facility.
- Fraud prevention services – Before we provide goods and services to you, we may use third parties to undertake fraud and money laundering checks and verify your identity. These organisations will report to us on industry fraud indicators and if they have reason to believe an identity is fraudulent. If we have reason to suspect fraud or other criminal offences we will pass your personal information to fraud prevention agencies or law enforcement agencies for the detection, investigation and prevention of crime. If we think there is a risk of fraud, we may suspend activity on your account or refuse access to your account and/or cancel an order. If we do this we will inform you by email or SMS and ask you to contact us.
- Debt collection agencies (DCAs) – If you default on repayments to your credit account we may share your data with DCAs to allow them to collect the outstanding debts from you.
- Debt purchase companies –Where appropriate will share certain information on defaulted accounts with prospective debt purchasers as part of the negotiations for sale of the debt.
- Debt management companies –where we have received appropriate instruction we will share information about your credit account with debt management companies to allow them to assist you with managing your debts.
- Research and analytics companies –We may share personal details to allow research companies and feedback providers to contact you directly on our behalf in order to capture your opinions on our products, services, websites and apps. We may ask these research companies to analyse the results so that we can better understand your online experience, which will help us to improve our services. We only provide them with the information they need to perform their function. This may take the form of a survey, where you may be asked to review a product or service you’ve bought or provide general feedback on our products and services. You will always have the choice about whether to take part in our market research or surveys. We may share information with specialist companies to analyse customer information to help us better understand how you use our services and to tailor products, services and offers that may be relevant for you. We utilise companies that help us track and record the way you navigate our website, so that we can understand your online experience and use it to improve our services and offer a more personalised experience.
- Product technicians – We use professional third party companies to assist us in independently reviewing issues and complaints with our products. We will share information with these technicians to allow them to review the product and return it to you or to review the product in your home.
- General service companies – Such as insurance companies, printers and mailing houses that assist us in providing our products and services.
- Regulators and law enforcement –We will share data with regulators and other official bodies (including law enforcement such as the Police) if they make formal requests or pursuant to legal proceedings
Our main operations are based in the UK and your personal information is generally processed, stored and used within the UK and other countries in the European Economic Area (EEA). In some instances your personal information may be processed outside the European Economic Area. For example, ACCURETTA operates a call center in Colombo, Sri Lanka. Operatives in this location will have access to your account information in order to assist you with your query. We also work with suppliers and partners who may make use of Cloud and /or hosted technologies across multiple geographies.
If and when this is the case we take steps to ensure there is an appropriate level of security so your personal information is protected in the same way as if it was being used within the UK.
Where we need to transfer your data outside of the UK or EEA we will use one of the following safeguards:
- The European Commission approved standard contractual clauses in contracts for the transfer of personal data to third countries.
- The International Data Transfer Agreement and Addendum for the transfer of personal information to third countries.
- Other EU approved mechanisms, as required by data protection legislation. More information of these measures can be found at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/rules-international-transfers-personal-data_en.
In Short: We may use cookies and other tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.
6. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
7. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at hello@luvander.com.
How do we protect personal information?
No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of any unauthorized access to your personal information, we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
Some of our websites permit you to create an account. When you do so, you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account.
Where is personal information stored and processed?
Our employees involved in data processing and our servers are based in Columbus, Ohio, US, and other locations throughout the United States. We work with affiliated and unaffiliated service providers in the United States, the United Kingdom, India, China, and other jurisdictions around the world.
8. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your personal information.You may review, change, or terminate your account at any time.
In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section ‘HOW CAN YOU CONTACT US ABOUT THIS NOTICE?‘ below.
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.
If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section ‘HOW CAN YOU CONTACT US ABOUT THIS NOTICE?‘ below.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications:You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, replying ‘STOP’ or ‘UNSUBSCRIBE’ to the SMS messages that we send, or by contacting us using the details provided in the section ‘HOW CAN YOU CONTACT US ABOUT THIS NOTICE?‘ below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
Account Information
If you would at any time like to review or change the information in your account or terminate your account, you can:
- Log in to your account settings and update your user account.
- Contact us using the contact information provided.
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.
If you have questions or comments about your privacy rights, you may email us at hello@luvander.com.
9. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (‘DNT’) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: If you are a resident of California, Colorado, Connecticut or Virginia, you are granted specific rights regarding access to your personal information.
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12) months:
| Category | Examples | Collected |
A. Identifiers | Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name | YES |
B. Protected classification characteristics under state or federal law | Gender and date of birth | NO |
C. Commercial information | Transaction information, purchase history, financial details, and payment information | YES |
D. Biometric information | Fingerprints and voiceprints | NO |
E. Internet or other similar network activity | Browsing history, search history, online behaviour, interest data, and interactions with our and other websites, applications, systems, and advertisements | NO |
F. Geolocation data | Device location | YES |
G. Audio, electronic, visual, thermal, olfactory, or similar information | Images and audio, video or call recordings created in connection with our business activities | NO |
H. Professional or employment-related information | Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us | NO |
I. Education Information | Student records and directory information | NO |
J. Inferences drawn from collected personal information | Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics | NO |
| K. Sensitive personal information | NO |
| L. Personal information as defined in the California Customer Records statute | Name, contact information, education, employment, employment history, and financial information | YES ( NAME , CONTACT INFORMATION) |
We will use and retain the collected personal information as needed to provide the Services or for:
- A. Identifiers – As long as the user has an account with us
We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
- Receiving help through our customer support channels;
- Participation in customer surveys or contests; and
- Facilitation in the delivery of our Services and to respond to your inquiries.
How do we use and share your personal information?
Learn about how we use your personal information in the section, ‘HOW DO WE PROCESS YOUR INFORMATION?‘
More information about our data collection and sharing practices can be found in this privacy notice.
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about who we disclose personal information to in the section, ‘WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?‘
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be ‘selling’ of your personal information.
We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Wewill not sell or share personal information in the future belonging to website visitors, users, and other consumers.
California Residents
California Civil Code Section 1798.83, also known as the ‘Shine The Light’ law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).
CCPA Privacy Notice
This section applies only to California residents. Under the California Consumer Privacy Act (CCPA), you have the rights listed below.
The California Code of Regulations defines a ‘resident’ as:
(1) every individual who is in the State of California for other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is outside of the State of California for a temporary or transitory purpose
All other individuals are defined as ‘non-residents’.
If this definition of ‘resident’ applies to you, we must adhere to certain rights and obligations regarding your personal information.
Your rights with respect to your personal data
Right to request deletion of the data — Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.
Right to be informed — Request to know
Depending on the circumstances, you have a right to know:
- whether we collect and use your personal information;
- the categories of personal information that we collect;
- the purposes for which the collected personal information is used;
- whether we sell or share personal information to third parties;
- the categories of personal information that we sold, shared, or disclosed for a business purpose;
- the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
- the business or commercial purpose for collecting, selling, or sharing personal information; and
- the specific pieces of personal information we collected about you.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Right to Limit Use and Disclosure of Sensitive Personal Information
We do not process consumer’s sensitive personal information.
Verification process
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
Other privacy rights
- You may object to the processing of your personal information.
- You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
- You can designate an authorised agent to make a request under the CCPA on your behalf. We may deny a request from an authorised agent that does not submit proof that they have been validly authorised to act on your behalf in accordance with the CCPA.
- You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.
To exercise these rights, you can contact us by visiting hello@luvander.com, by emailing hello@luvander.com, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.
Colorado Residents
This section applies only to Colorado residents. Under the Colorado Privacy Act (CPA), you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.
- Right to be informed whether or not we are processing your personal data
- Right to access your personal data
- Right to correct inaccuracies in your personal data
- Right to request deletion of your personal data
- Right to obtain a copy of the personal data you previously shared with us
- Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (‘profiling’)
To submit a request to exercise these rights described above, please email hello@luvander.com or visit hello@luvander.com.
If we decline to take action regarding your request and you wish to appeal our decision, please email us at hello@luvander.com. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.
Connecticut Residents
This section applies only to Connecticut residents. Under the Connecticut Data Privacy Act (CTDPA), you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.
- Right to be informed whether or not we are processing your personal data
- Right to access your personal data
- Right to correct inaccuracies in your personal data
- Right to request deletion of your personal data
- Right to obtain a copy of the personal data you previously shared with us
- Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that product legal or similarly significant effects (‘profiling’)
To submit a request to exercise these rights described above, please email hello@luvander.com or visit hello@luvander.com.
If we decline to take action regarding your request and you wish to appeal our decision, please email us at hello@luvander.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.
Virginia Residents
Under the Virginia Consumer Data Protection Act (VCDPA):
‘Consumer’ means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.
‘Personal data’ means any information that is linked or reasonably linkable to an identified or identifiable natural person. ‘Personal data’ does not include de-identified data or publicly available information.
‘Sale of personal data’ means the exchange of personal data for monetary consideration.
If this definition ‘consumer’ applies to you, we must adhere to certain rights and obligations regarding your personal data.
Your rights with respect to your personal data
- Right to be informed whether or not we are processing your personal data
- Right to access your personal data
- Right to correct inaccuracies in your personal data
- Right to request deletion of your personal data
- Right to obtain a copy of the personal data you previously shared with us
- Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (‘profiling’)
Exercise your rights provided under the Virginia VCDPA
You may contact us by email at hello@luvander.com or visit hello@luvander.com.
If you are using an authorised agent to exercise your rights, we may deny a request if the authorised agent does not submit proof that they have been validly authorised to act on your behalf.
Verification process
We may request that you provide additional information reasonably necessary to verify you and your consumer’s request. If you submit the request through an authorised agent, we may need to collect additional information to verify your identity before processing your request.
Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.
Right to appeal
If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at hello@luvander.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal if denied, you may contact the Attorney General to submit a complaint.
11. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated ‘Revised’ date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at hello@luvander.com or contact us by post at:
ACCURETTA SYSTEMS LIMITED
Unit 13 Freeland Park Wareham Road, Lytchett Matravers,
Poole BH16 6FA
England
13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please visit: hello@luvander.com.