Privacy Policy
This Privacy Policy sets out how we, LumiHand, collect, store and use information about you when you use or interact with our website lumihand.com (our website) and where we otherwise obtain or collect information about you.
This Privacy Policy is effective from 11th January 2022.
Contents
- Summary
- Our Details
- Information we collect when you visit our website
- Information we collect when you contact us
- Information we collect when you interact with our website
- Information we collect when you place an order on our website
- Information collected or obtained from third parties
- Disclosure and additional uses of your information
- How long we retain your information
- How we secure your information
- Transfers of your information outside the European Economic Area
- Your rights in relation to your information
- Your right to object to the processing of your information for certain purposes
- Sensitive Personal Information
- Changes to our Privacy Policy
- Children’s Privacy
- Copyright, credit and logo
This section summarises how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.
How we collect or obtain information about you
when you provide it to us (e.g. by contacting us, placing an order on our website, when you register with us or if you subscribe to e-mail marketing.
from your use of our website, using cookies and web beacons
occasionally, from third parties
Information we collect: name, address, contact details
Information analytic software collects: information from cookies, information about your computer or device (e.g. device and browser type), information about how you use our website (e.g. which pages you have viewed, the time when you view them and what you clicked on, the geographical location from which you accessed our website (based on your IP address.
How we use your information: for administrative and business purposes (particularly to contact you and process orders you place on our website), to improve our business and website, to fulfil our contractual obligations, to advertise our goods and services and to analyse your use of our website.
Disclosure of your information to third parties: only to the extent necessary to run our business, to our service providers, to fulfil any contracts we enter into with you, where required by law or to enforce our legal rights.
Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event): No.
How long we retain your information: for no longer than necessary, taking into account any legal obligations we have , any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business) For specific retention periods in relation to certain information which we collect from you, please see the main section below entitled How long we retain your information.
How we secure your information: using appropriate technical and organisational measures such as storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology only granting access to your information where necessary. Payments are taken by an SSL secured payment gateway.
Use of cookies and similar technologies: we use cookies and similar information-gathering technologies such as web beacons on our website including essential, functional, analytical and targeting cookies.
We would transfer your information outside the European Economic Area if we are required to do so by law.
Use of automated decision making and profiling: we do not use automated decision making and profiling. We use web analytics, cookies, web beacons or server logs analysis tools (profiling) to enhance and improve the website optimising performance and tailoring messaging to users.
Your rights in relation to your information
To access your information and to receive information about its use
To have your information corrected and/or completed
To have your information deleted
To restrict the use of your information
To receive your information in a portable format
To object to the use of your information
To withdraw your consent to the use of your information
Not to have significant decisions made about you based solely on automated processing of your information, including profiling
To complain to a supervisory authority
Sensitive personal information: we do not knowingly or intentionally collect what is commonly referred to as ‘sensitive personal information'. Please do not submit sensitive personal information about you to us. For more information, please see the main section below entitled Sensitive Personal Information.
- Our Details
The data controller in respect of our website is Rapsly.com. You can contact the data controller by emailing hi@lumihand.com
If you have any questions about this Privacy Policy, please contact the data controller.
- Information we collect when you visit our website
We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.
Web server log information
The website is hosted and powered by Shopify, the privacy policy of which is available here: http://www.shopify.com/legal/privacy.
Use of website server log information for IT security purposes
Shopify collect(s) and store(s) server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber-attacks, by detecting unusual or suspicious activity.
Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation: we have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.
Legal basis for processing: our and a third party’s legitimate interest (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: we and our third-party hosting provider have a legitimate interest in using your information for the purposes of ensuring network and information security.
Cookies and similar technologies
Cookies are data files which are sent from a website to a browser to record information about users for various purposes.
We use cookies and similar technologies on our website, including essential, functional, analytical and targeting cookies and web beacons.
You can reject some or all of the cookies we use on or via our website by changing your browser settings.
For further information about cookies, including how to change your browser settings, please visit www.allaboutcookies.org.
- Information we collect when you contact us
We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.
When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).
Transfer and storage of your information
We use a third-party email provider to store emails you send us. Our third-party email provider is Gmail.
Contact form
When you contact us using our contact form, we collect name, email address, telephone number and any comments provided.
If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).
Transfer and storage of your information
Messages you send us via our contact form will be stored within the European Economic Area on our third party hosting server and Gmail.
Phone
When you contact us by phone, we collect your phone number and any information provide to us during your conversation with us.
We do not record phone calls
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).
Transfer and storage of your information
- Information we collect when you interact with our website
We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section entitled Disclosure and additional uses of your information.
E-Newsletter
When you sign up for our e-newsletter on our website or opt to receive news, offers, inspiration and competitions from us by entering your name and email address on our home page, and clicking subscribe or ticking a box at checkout or when registering indicating that you would like to receive your e-newsletter, we collect the given name, e-mail address, nearest store, marketing permissions and how you subscribed.
Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent to us sending you our e-newsletter by signing up to receive it using the steps described above.
Use of web beacons and similar technologies in emails
We use technologies such as web beacons (small graphic files) and cookies in the marketing emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates which our emails achieve. We will only use web beacons and cookies in our emails if you have consented to us doing so, when you click on the confirmation e-mail.
- Information we collect when you place an order on our website
We collect and use information from individuals who place an order on our website in accordance with this section and the section entitled Disclosure and additional uses of your information.
Information collected when you place an order
Mandatory Information
When you place an order for goods or services on our website, we collect your name, email address, billing address and shipping address.
If you do not provide this information, you will not be able to purchase goods or services from us on our website or enter into a contract with us.
Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: we need the mandatory information collected by our checkout form to establish who the contract is with and to contact you to fulfil our obligations under the contract, including sending you receipts and order confirmations.
Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation: we have a legal obligation to issue you with an invoice for the goods and services you purchase from us where you are VAT registered and we require the mandatory information collected by our checkout form for this purpose. We also have a legal obligation to keep accounting records, including records of transactions.
Optional information
We also collect optional information from you, such as your phone number. We also ask you if you would like to receive marketing communications from us. For further information, see ‘Marketing communications’ in this section below.
If you do not supply the optional information requested at checkout, such as phone number we will not be able to contact you by phone.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: to be able to contact the customer by phone where (if necessary) in relation to their order.
Processing your payment
After you place an order on our website you will need to make payment for the goods or services you have ordered. In order to process your payment, we use third party payment gateways, including Shopify Payments, Paypal and Amazon Pay. Your payment will be processed by these payment providers
Paypal collects, uses and processes your information, including payment information, in accordance with their privacy policies. You can access their privacy policies via the following link(s):
https://www.paypal.com/gb/webapps/mpp/ua/privacy-full
Transfer and storage of your information
Information relating to the processing of your payment is stored within the European Economic Area Paypal is located in Luxembourg.
For further information about payment processing refer to the third-party privacy policies above.
Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: to fulfil your contractual obligation to pay for the goods or services you have ordered from us.
Marketing Communications
At the checkout you will have the option of receiving marketing communications from us.
Our similar goods and services
You can opt-out from receiving marketing communications in relation to our goods and which are similar to those which you purchase from us, by ticking a box to opt out or selecting ‘unsubscribe’ at the bottom of the marketing e-mail.
We will send you marketing communications in relation to similar goods and services if you do not opt out from receiving them.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: direct marketing and advertising our products and services.
Use of web beacons and similar technologies in our marketing emails.
We use technologies such as web beacons (small graphic files) and similar technologies in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates which our emails achieve. We will only use web beacons and cookies in our emails if you have consented to us doing so.
Our goods and services
You can opt in to receiving marketing communications from us by e-mail in relation to our goods and services by using our signup form on the homepage, by clicking a box to indicate you would like to receive such communications upon registering or at our checkout, or you can contact us directly to add you to our list.
We will send you marketing communications in relation to our goods and services only if you opt-in to receive them.
Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent to us sending you information about our goods and services by signing up to receive such information in accordance with the steps described above.
Use of web beacons and similar technologies in marketing emails
We use technologies such as web beacons (small graphic files) similar technologies in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates and insert any additional information you measure about user interaction with your emails which our emails achieve. We will only use web beacons if you have consented to us doing so.
- Information collected or obtained from third parties
This section sets out how we obtain or collect information about you from third parties.
Information received from third parties
Generally, we do not receive information about you from third parties.
It is possible that third parties with whom we have had no prior contact may provide us with information about you.
Information we obtain from third parties will generally be your name and contact details,but will include any additional information about you which they provide to us.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where a third party has passed on information about you to us (such as your name and email address) in order for us to provide services to you, we will process your information in order to take steps at your request to enter into a contract with you and perform a contract with you (as the case may be).
Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: where you have asked that a third party to share information about you with us and the purpose of sharing that information is not related to the performance of a contract or services by us to you, we will process your information on the basis of your consent, which you give by asking the third party in question to pass on your information to us.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: where a third party has shared information about you with us and you have not consented to the sharing of that information, we will have a legitimate interest in processing that information in certain circumstances.
For example, we would have a legitimate interest in processing your information to perform our obligations under a sub-contract with the third party, where the third party has the main contract with you. Our legitimate interest is the performance of our obligations under our sub-contract.
Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.
Where we receive information about you in error: If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.
- Disclosure and additional uses of your information
We use a number of third parties to provide us with services which are necessary to run our business.
Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering goods and services from us e.g. carrier services.
We do not display the identities of all of our service providers publicly by name for security and competitive reasons. If you would like further information about the identities of our service providers, however, please contact us directly via our contact form or by email at hi@lumihand.com and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such service providers, for example).
Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest relied on: where we share your information with these third parties in a context other than where is necessary to perform a contract (or take steps at your request to do so), we will share your information with such third parties in order to allow us to run and manage our business efficiently.
Legal basis for processing: necessary to perform a contract and/or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: we may need to share information with our service providers to enable us to perform our obligations under that contract or to take the steps you have requested before we enter into a contract with you.
Disclosure of your information to other third parties
We disclose your information to other third parties in specific circumstances, as set out below.
Providing information to third parties such as Google Inc. Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): meeting our contractual obligations to Google under our Google Analytics Terms of Service (https://www.google.com/analytics/terms/us.html)
You can opt out of Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout
Transfer and storage of your information
Information collected by Google Analytics is stored outside the European Economic Area on Google’s servers in the United States of America.
For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
- How long we retain your information
This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.
Retention Periods
Order information: when you place an order for goods and services, we retain that information for six years following the end of the financial year in which you placed your order, in accordance with our legal obligation to keep records for tax purposes.
Correspondence and enquiries: when you make an enquiry or correspond with us for any reason, whether by email or via our contact form or by phone we will retain your information for as long as it takes to respond to and resolve your enquiry.
E-Newsletter:. we retain the information you used to sign up for our e-newsletter for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our e-newsletter service, whichever comes earlier.
Criteria for determining retention periods
In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:
the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
whether we have any legal basis to continue to process your information (such as your consent);
how valuable your information is (both now and in the future);
any relevant agreed industry practices on how long information should be retained;
the levels of risk, cost and liability involved with us continuing to hold the information;
how hard it is to ensure that the information can be kept up to date and accurate; and
any relevant surrounding circumstances (such as the nature and status of our relationship with you).
- How we secure your information
We take appropriate technical and organizational measures to secure your information and to protect it against unauthorized or unlawful use and accidental loss or destruction, including:
only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
using secure servers to store your information;
verifying the identity of any individual who requests access to information prior to granting them access to information;
using Secure Sockets Layer (SSL) software to encrypt.
Transmission of information to us by email
Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.
We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.
- Transfers of your information outside the European Economic Area
Google Analytics
Information collected by Google Analytics (your IP address and actions you take in relation to our website) is transferred outside the EEA and stored on Google’s servers. You can access Google’s privacy policy here: https://www.google.com/policies/privacy/
Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.
Safeguard(s) used: Google has self-certified its compliance with the EU-U.S. Privacy Shield which is available here: https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm
- Your rights in relation to your information
Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by emailing hi@lumihand.com
to request access to your information and information related to our use and processing of your information;
to request the correction or deletion of your information;
to request that we restrict our use of your information;
to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);
to object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and
to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.
In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.
Further information on your rights in relation to your personal data as an individual
The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO’s website:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/; and
https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/
You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here: http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf
Verifying your identity where you request access to your information
Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.
These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorized access to your information.
How we verify your identity
Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.
If it is not possible to identify you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.
We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.
- Your right to object to the processing of your information for certain purposes
You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by emailing hi@lumihand.com
to object to us using or processing your information where we use or process it in order to carry out a task in the public interest or for our legitimate interests, including ‘profiling’ (i.e. analyzing or predicting your behavior based on your information) based on any of these purposes; and
to object to us using or processing your information for direct marketing purposes (including any profiling we engage in that is related to such direct marketing).
You may also exercise your right to object to us using or processing your information for direct marketing purposes by:
clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;
sending an email to hi@lumihand.com, asking that we stop sending you marketing communications or by including the words “OPT OUT”.
- Sensitive Personal Information
‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.
We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.
If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.
- Changes to our Privacy Policy
We update and amend our Privacy Policy from time to time.
Minor changes to our Privacy Policy
Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.
Major changes to our Privacy Policy or the purposes for which we process your information
Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.
We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.
Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.
- Children’s Privacy
Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.
It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to hi@lumihand.com
- Copyright, credit and logo
This Privacy Policy is based on a General Data Protection Regulation (Regulation (EU) 2016/769) (GDPR) compliant template provided by GDPR Privacy Policy. For further information, please visit https://gdprprivacypolicy.org.
The copyright in this Privacy Policy is either owned by, or licensed to, us and is protected by copyright laws around the world and copyright protection software. All intellectual property rights in this document are reserved.
Where we display the GDPR Privacy Policy logo on our website, this is used to indicate that we have adopted a privacy policy template provided by GDPR Privacy Policy as the basis for this Privacy Policy.
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