Privacy Policy
We at Luxe Smart Homes Limited (referred to as “we/us/our”) understand that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of our clients, prospective clients and everyone else who visits our website (www.luxesmarthomes.co.uk) and we will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
1. What Does This Policy Cover?
1.1 This Privacy Policy explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
1.2 Our website may contain links to other websites. Please note that we have no control over how your data is collected, stored or used by other sites and we advise you to check the privacy policies of any such sites before providing any data to them.
2. What Is Personal Data?
2.1 Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as “any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier”.
2.2 Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
2.3 The personal data that we collect is set out in clause 5, below.
3. Your Rights
3.1 Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
3.1.1 The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions;
3.1.2 The right to access the personal data we hold about you. Clause 8 will tell you how to do this;
3.1.3 The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete;
3.1.4 The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold;
3.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
3.1.6 The right to object to us using your personal data for a particular purpose or purposes;
3.1.7 The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time;
3.1.8 The right to data portability. This means that, if you have provided personal data to us directly, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases; and
3.1.9 Rights relating to automated decision-making and profiling.
3.2 For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in clause 10.
3.3 It is important that your personal data is kept accurate and up to date. If any of the personal data we hold about you changes, please keep us informed for as long as we have that data.
3.4 Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
3.5 If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in clause 10.
4. What Data Do We Collect?
4.1 We are the data controller, and we are responsible for your personal data.
4.2 We may collect and hold some or all of the personal data set out below. We do not collect any “special category” or “sensitive” personal data, or data relating to criminal convictions and/or offences.
4.3 Most of the personal information we process is provided to us by you for one of the following reasons:
Direct Interactions
You may provide us with your Identity/Contact data by corresponding with us by post, phone or email. This includes personal data you provide when you:
· contact us about our products and services;
· request marketing information to be sent to you;
· provide us with feedback.
Automated technologies or interactions
As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Further information about cookies can be found in clause 9.
Third parties or publicly available sources
We may receive personal data about you from various third parties, including technical data from the following parties:
· analytics providers;
· advertising networks; and
· search information providers such as Google
some of which may based outside of the UK.
4.4 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Data Collected
“Identity” Information including first names and last names.
“Contact” information including addresses, email addresses and telephone numbers.
“Financial” information including bank account and payment details.
“Transaction” information including details about payments to and from you, and other details of products and services you have purchased from us.
“Technical” information including internet protocol (IP) address, 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 our website.
“Profile” information including your interests, preferences, feedback and survey responses.
“Usage” information including information about how you use our website and our products and services.
“Marketing and Communications” information including your preferences in receiving marketing from us and our third parties, and your communication preferences.
4.5 We may use online advertising to keep you aware of what we’re up to and to help you find information about our products and services. Like many companies, we may target banners and ads to you when you use other websites and apps, based on your Contact, Technical, Usage and Profile Data. We do this using a variety of digital marketing networks and ad exchanges, and a range of advertising technologies such as web beacons, pixels, ad tags, cookies, and mobile identifiers, as well as specific services offered by some sites and social networks.
5. How Do We Use Your Data?
5.1 All personal data is processed and stored securely, for no longer than is necessary or statutorily required in light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights under the applicable Data Protection Legislation at all times. For more details on security see clause 6, below.
5.2 Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your personal data (e.g. by subscribing to emails), or because it is in our legitimate interests. Specifically, we may use your data for the following purposes:
5.3 Please be aware that as a client, if you provide us with, or allow us access to, the personal data of any other person, it is your responsibility to obtain permission from those persons to pass their data to us, as a third party. We will only use that data as set out above to provide our services and will not use it for any other purpose.
5.4 With your permission and/or where permitted by law, we may also use certain data for marketing purposes which may include contacting Clients by email with information, news and offers. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the applicable Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003. Clients may also opt out of receiving certain marketing emails from us by unsubscribing using the links provided in our emails and at the point of providing your details.
5.5 You have the right to withdraw your consent to us using your personal data at any time, and to request that we delete it. Unless we have reasonable grounds to refuse to delete it (where this is permitted under the applicable Data Protection Legislation), we will do so without delay and within no longer than one month from receiving your request.
6. How and Where Do We Store Your Data?
6.1 We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the periods specified in the table above (or, where there is no fixed period, the same factors will be used to determine how long it is kept).
6.2 All personal data we process is encrypted, including any back-ups.
6.3 The majority of your personal data will be stored in the UK. However, we may store some of your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.
6.4 We will not store any of your personal data outside of the EEA.
6.5 The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including limiting access to your personal data to those employees, agents, sub-contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality; and procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.
7. Do We Share Your Personal Data?
7.1 We may sometimes contract with other third parties to supply products and services to you on our behalf, such as sub-contractors, and in some cases, these third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law.
7.2 If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.
7.3 In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
7.4 If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in clause 6.
7.5 If any personal data is transferred outside of the UK, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in clause 6.
8. How Can You Access Your Personal Data?
8.1 If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”. All subject access requests should be made in writing.
8.2 There is not normally any charge for a subject access request. If your request is “manifestly unfounded or excessive” (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
8.3 We will respond to your subject access request within 5 working days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
9. Our Use of Cookies
9.1 All cookies used by and on our website are used in accordance with current cookie law.
9.2 We may place and access first party and third-party cookies on your computer or device, to facilitate and improve your experience of our website and to provide and improve our products and services.
9.3 You can view the list of cookies our website uses, by clicking on the padlock icon in the search bar. You can also block and remove certain cookies in this way.
9.4 First party cookies are those placed directly by us and are used only by us. Third party cookies are those placed by websites and/or parties other than us. These cookies are not integral to the functioning of our website and your use and experience of our website will not be impaired by refusing consent to them.
9.5 Before cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those cookies. By giving your consent to the placing of cookies, you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of cookies, however certain features of our website may not function fully or as intended.
9.6 Certain features of our website depend on cookies to function. Cookie law deems these cookies to be “strictly necessary”. Your consent will not be sought to place these cookies, but it is still important that you are aware of them. You may still block these cookies by changing your internet browser’s settings, but please be aware that our website may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
9.7 Our website uses Google Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how our website is used. This, in turn, enables us to improve our website and the products and services offered through it. You do not have to allow us to use these cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of our website, it does enable us to continually improve our website, making it a better and more useful experience for you. Google's privacy policy is available at: https://policies.google.com/privacy
9.8 You can choose to delete cookies on your computer or device at any time, however you may lose any information that enables you to access our website more quickly and efficiently.
9.9 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
10. Contacting Us
If you have any questions about how we use your data or this Privacy Policy, please contact us using any of the methods on our contact page. Please ensure that your query is clear, particularly if it is a request for information about the data we hold about you (as under clause 8, above).
11. Changes to this Privacy Policy
We may change this Privacy Policy from time to time (if, for example, if the law changes). Any changes will be made available on our website and you will be deemed to have accepted the terms of the Privacy Policy on your visit to our website following the alterations. We recommend that you check this page regularly to keep up to date.
