This policy applies where we are acting as a data controller with respect to your personal data
WHAT PERSONAL DATA DO WE COLLECT?
We collect and process only the data that is required to allow us to provide our services to you.
In particular, we collect personal information about you when you register or subscribe for one of our services, place an order, use our online services, interact with us in any other way, such as via social media, click on an advert that we put on our or someone else’s website.
By registering, subscribing or using our services, you consent to the use of your personal data in line with this policy.
We collect the following data when you browse or shop at www.trading-lux.com.
- We process the personal data required to complete your purchase including payment details and email address. We collect your email address in order to send you confirmation of your order.
- We collect your email address when you sign up to receive Trading-lux news.
- If you register for a Trading-Lux’s account, we may collect your email address, password.
- When you contact our customer care team, we may collect additional data such as name, phone number, address, date of birth to help us resolve any queries relating to your subscription order, payments, marketing, the website or any other queries.
- We collect and process data about your browsing on trading-lux.com, including the pages you visit and how you interact with these pages. If you have registered for an account, we collect browsing data about your access to the dedicated areas of the website.
- We collect and process your personal data for direct marketing only after you have given us your consent.
- When you call our Customer Care team, your call will be recorded for training and fraud prevention purposes.
- Some data are collected when you provide it to us. This could, for example, be data you enter on a contact form. Other data are collected automatically by our IT systems when you visit the website. These data are primarily technical data as the browser and operating system you are using or when you accessed the page. These data are collected automatically as soon as you enter our website.
Site traffic, sales, wish lists, and other commercial information which we may pass onto third parties, but this information does not include any details which can identify you personally.
WHEN DO WE USE THE PERSONAL DATA WE COLLECT?
Some data are collected when you provide it to us. This could, for example, be data you enter on a contact form. Other data are collected automatically by our IT systems when you visit the website. These data are primarily technical data such as the browser and operating system you are using or when you accessed the page. These data are collected automatically as soon as you enter our website.
HOW DO WE USE THE PERSONAL DATA WE COLLECT?
Whenever you give us your personal information we will use it in accordance with applicable privacy laws and for the purposes set out in this policy, on the data entry forms you complete, in any relevant terms and conditions and on pages or emails which link to the data entry forms.
We collect and process your personal data for the following purposes:
- To fulfil our contract with you, including taking payment (shipping and delivery)
- To provide you with relevant information about our products and services via our marketing communications and advertising ONLY UPON PRIOR WRITTEN AGREEMENT
- To help you take full advantage of our website, including using services such as Wish Lists
- To allow our Customer Care team to help you with queries and requests
- To provide communications about fraud prevention checks
- To prevent potentially prohibited or illegal activities, and enforce our User Agreement;
- To customize, measure and improve our services, content and advertising;
Saved payment card details will only be shared with our payment partner and not with any other third parties and will only be used to process your order, using our payment partner’s systems.
Contact form: Should you send us questions via the contact form, we will collect the data entered on the form, including the contact details you provide, to answer your question and any follow-up questions. We do not share this information without your permission.
We will, therefore, process any data you enter onto the contact form only with your consent per Art. 6 (1)(a) GDPR. You may revoke your consent at any time. An informal email making this request is sufficient. The data processed before we receive your request may still be legally processed.
We will retain the data you provide on the contact form until you request its deletion, revoke your consent for its storage, or the purpose for its storage no longer pertains (e.g. after fulfilling your request). Any mandatory statutory provisions, especially those regarding mandatory data retention periods, remain unaffected by this provision.
Our use of your data is necessary for our legitimate interest in ensuring that you receive information relating to our contract with you.
Newsletter data: If you would like to receive our newsletter, we require a valid email address as well as information that allows us to verify that you are the owner of the specified email address and that you agree to receive this newsletter. No additional data is collected or is only collected on a voluntary basis. We only use this data to send the requested information and do not pass it on to third parties.
We will, therefore, process any data you enter onto the contact form only with your consent per Art. 6 (1) (a) RGDP. You can revoke consent to the storage of your data and email address as well as their use for sending the newsletter at any time, e.g. through the “unsubscribe” link in the newsletter. The data processed before we receive your request may still be legally processed.
The data provided when registering for the newsletter will be used to distribute the newsletter until you cancel your subscription when said data will be deleted. Data we have stored for other purposes (e.g. email addresses for the members area) remain unaffected.
WHAT IS OUR LEGAL BASIS
Under the Law we must have a valid reason for using your personal data and we may not collect, store or use data about you that is not compatible with that reason. There are four valid reasons for our use of your personal data:
a- Most of the data we collect from you is necessary to allow us to fulfil our contract with you or to enter into a contract with you e.g. you provide a billing address and email address when you purchase an item from www.trading-lux.com so that we can process your payment and send you order confirmation.
b- In certain circumstances we will ask for your permission or consent to use your personal data e.g. if we would like to send you marketing information about items we believe may be of interest to you via email. If you have given your consent to our use of your personal data, you are entitled to withdraw this consent at any time.
c- We may also have a legitimate interest in using your personal data e.g. to ensure that the content of our website is presented to you and your device as effectively as possible, or to ensure that our marketing communications are relevant to your interests. If this is our reason for using your data, we must make sure that our interests do not override yours and you are entitled to object to this use of your data.
- d) Lastly, we may be required to use your data to meet a legal obligation or to protect your interests e.g. we may exchange information with other specialist organisations for the purposes of fraud detection and credit risk reduction and we will retainfinancial data long term to meet our statutory
We shall only send personal data collected within the European Economic Area (EEA) to non-EEA states in case such transfer is requested by you, in order to comply with a legal obligation or to work with third party service providers who we use to help run our business and services. In doing so, we shall comply with all relevant data protection rules and regulations.
WHO WILL PROCESS YOUR DATA?
Your personal data will be processed by the internal staff of Trading Lux who have been specifically trained and authorised for this processing.
We may also share or match your data with third party business partners to provide you with the products, services or information you ask for.
These parties have been rigorously assessed and offer a guarantee of compliance with the legislation on the processing of personal data. These parties have been designated as data processors and carry out their activities according to the instructions given by Trading-Lux and under its control.
The third parties in question belong to the following categories: banking operators, internet providers, companies specialising in IT and telematics services, companies that carry out marketing activities, including social media organisations, fraud prevention agencies, companies specialized in market research and data processing, companies offering contact centre services, companies providing publishing and distribution services.
Under some circumstances we may be required to disclose or share your data without your consent, for example if we are required by the police, the courts or for other legal reasons. Your data may be transmitted to the police, judicial and administrative authorities, in accordance with the law, for the investigation and prosecution of crimes, the prevention of and protection from threats to public security, to allow Trading Lux to ascertain, exercise or defend a right in court, as well as for other reasons related to the protection of the rights and freedoms of others.
Only you or, upon your request, our Customer Care team, may access your personal data from our online services using your user ID and password. Information may be changed online within “My Account”. You can change or delete saved credit/debit card details each time you make a purchase.
Link to other websites: Our online services contain hyperlinks to websites that are owned and operated by other organisations. These websites have their own privacy and cookie policies, and we urge you to read them. They control how your personal information is used when you give it to these other organisations or they collect it with cookies. We do not approve any other websites and we are not responsible for any information, material, products or services that are on or accessible through those websites or for the privacy practices of websites run by other organisations. If you use these other websites you do so at your own risk.
We use “Google Recaptcha” on our website. This service is provided by Google Inc.
Recaptcha is used to check whether the data entered on our website (such as on a contact form) has been entered by a human or by an automated program. To do this, recaptcha analyzes the behaviour of the website visitor based on various characteristics. This analysis starts automatically as soon as the website visitor enters the website. For the analysis, recaptcha evaluates various information (e.g. IP address, how long the visitor has been on the website, or mouse movements made by the user). The data collected during the analysis will be forwarded to Google.
HOW LONG DO WE KEEP YOUR DATA?
We keep your personal data for a limited period of time in line with our data retention policy. The specific retention period will vary according to the reason for processing your personal data. After this period, your data will be permanently erased or otherwise irreversibly rendered anonymous.
Your personal data are retained in accordance with the following criteria:
When you have purchased goods from www.trading-lux.com, we will retain the billing data until the end of the relevant accounting period, normally seven years from the billing date.
When you make a payment, we will retain your payment details up to the certification of the payment and the completion of the relevant administrative-accounting formalities regarding your right of withdrawal and the terms applied for the disputing of the payment.
When you provide us with personal data in order to use the services of www.trading-lux.com, such as marketing communications subscription, we will keep your data for this purpose until the termination of the service or until you cancel your subscription to the service.
When you give us your consent to send you marketing communications, you can withdraw your consent at any time. We will consider your consent to be current for five years from your last interaction with any email that we send you with www.trading-lux.com. In any case, we will reduce the number of marketing contacts after six months if you don’t interact with us.
When we use your personal data and browsing history to analyse your behaviour in order to customise the website and to show you personalised sales offers, we will keep the data for analytical purposes until you ask us to delete it.
When we use personal data for market research and satisfaction surveys, we will keep the data until you ask us to stop.
When you contact our Customer Care team, we will keep any additional personal data you provide that is specific to your enquiry for as long as you remain an active customer of www.trading-lux.com.
When you contact our Customer Care team, we will keep the call recording for 6 months. Credit card details are not recorded as part of the call.
You have the right to request a copy of the data that we hold about you (and we will provide this to you free of charge once we have confirmed your identity).
If you would like a copy of some or all of your personal data, please email or write to us using the contact details in this policy.
If we do hold data about you we will:
- give you a description of it
- tell you why we are holding it
- tell you who it could be shared with
- tell you how long we will keep the data
- if the data was not provided by you, we will give you any available information such as the source of the data
- tell you if the data is stored outside of the European Economic Area, and if so what safeguards are in place to protect your personal data
- let you have a concise and clear copy of the data
You have the right to ask us to correct any inaccuracies in the personal data we hold about you and to stop us using your data until it has been corrected. We want to make sure that your personal data is accurate and up to date and we will be happy to correct or remove data you think is inaccurate. You can also update your own information at any time by logging into My Account at www.trading-lux.com
You have the right to withdraw your consent to marketing at any time by calling our Customer Care team or by clicking “unsubscribe” on a marketing email. Alternatively, you can sign in to your account on www.trading-lux.com and update your requirements in our Email Preference Centre.
You have the right to request the deletion of your personal data. After receiving and reviewing your request, if legitimate it will be our responsibility to cease processing promptly and to delete your personal data.
You have the right to receive a copy of your data that we process based on your consent or on the basis of a contract with you in a standard format.
To exercise any of these rights, you can sign in to your account, contact our Customer Care team at firstname.lastname@example.org or +33 755314423.
To ensure that the data of our users are not subject to breaches or illegitimate use by third parties, we will ask you to confirm your identity before carrying out your request.
We protect your personal data with specific technical and organisational security measures aimed at preventing your personal data from being used illegitimately or fraudulently by third parties.
In particular, we use security measures that guarantee: pseudonymisation or encryption of your data, the confidentiality, integrity, and availability of your data as well as the resilience of the systems and services that process them, the ability to restore data in the event of a data breach.
We take reasonable care to maintain appropriate safeguards to ensure the security, integrity and privacy of the information you have provided to us. We have put in place technology and security policies which are designed to protect the personal information we hold about you. We also follow the security procedures that applicable privacy laws require. These cover storing, using and releasing any information you have provided and, as well as measures designed to prevent unauthorised access or use. When you place an order or access your account information, we use a Secure Socket Layer (SSL) encryption which encrypts your information before it is sent to us to protect it from unauthorised use.
Payment transactions using common means of payment (Visa/MasterCard, direct debit) are only made via encrypted SSL or TLS connections. You can recognize an encrypted connection in your browser’s address line when it changes from “http://” to “https://” and the lock icon in your browser line is visible.
In the case of encrypted communication, any payment details you submit to us cannot be read by third parties.
Furthermore, Trading-Lux undertakes to test, verify and regularly evaluate the effectiveness of technical and organizational measures in order to guarantee continuous improvement in the safety of processing.
CHANGES TO THIS NOTICE
LEGISLATIVE REFERENCES AND USEFUL LINKS
The processing of your personal data is carried out by Trading-lux.com in compliance with the Regulation (EU) 2016/679 general regulation on data protection.