Anaco UK Limited (t/a LUMA)
98 Church Road
Tel: 020 8748 2264 VAT Number: 877 6598 43
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
3.1 This version was last updated on 29/05/2018. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
4. When do we collect personal data from you
4.1 We may collect and process the following data about you:
• When you make an online purchase
• When you purchase a product in store or by phone
• When you sign up for our email newsletter
• When you engage with us on social media
• When you contact us by any means with queries, complaints, etc
• When you enter prize draws or competitions
• When you complete any surveys we send you
• When you comment on or review our products and services
• When you've given a third party permission to share with us information they hold about you
• We collect data from publicly-available sources when you have given consent to share information or where the information is made public as a matter of law
• When you visit our shop, which usually has CCTV systems operated for the security of both customers and staff
• When you apply for a trade account with us through our website, over the phone and in-store
5. Personal data we may collect from you
5.1 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 follows:
• Identity Data including first name, last name, title. Your image may be recorded on CCTV when you visit our shop.
• Contact Data including billing address, delivery address, email address, telephone numbers. We will also collect your social media username, if you interact with us through those channels.
• Financial Data including bank account and payment card details
• Transaction Data including details about payments to and from you and other details of products you have purchased from us
• To deliver the best possible web experience, we collect Technical Data 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 Data including purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
6. How and why we use your personal data
6.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
6.2 Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. If you wish to change how we use your data, see 10. How long will you keep my data for? for more information. Remember, if you choose not to share personal data with us, or refuse certain contact permissions, we might not be able to provide some services you asked for.
Examples of how we use information held about you include:
• To process any orders that you make on our website or in store. If we don't collect your personal data during checkout, we won't be able to process and deliver your order and comply with legal obligations. For example, your details may need to be passed to a third party to supply or deliver the product or service that you ordered, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds, guarantees and so on.
• To respond to your queries, refund requests and complaints. Handling the information you send enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
• To protect our customers, premises, assets and staff from crime, we operate CCTV systems in our shop that record images for security. We do this on the basis of our legitimate business interests.
• To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
• If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim to protect the individuals we interact with from criminal activities.
• To listen to recorded telephone conversations for internal staff training.
• To send you relevant communications by email or post in relation to updates, products and services. We'll do this on the basis of our legitimate business interest. You are free to opt out of hearing from us by email or post at any time. For information on how to opt out go to section 11. What are your rights over your personal data?
• To administer any of our prize draws or competitions which you enter
• To develop, test and improve the systems, services and products we provide to you. We'll do this on the basis of our legitimate business interests.
• To comply with our contractual or legal obligations to share data with law enforcement.
• To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you.
• To build a picture of who you are and your interests, and to inform our business decisions, we'll combine data captured by LUMA, third parties and data from publicly-available lists as we have described in the section 'Personal Data we collect from you?' We'll do this on the basis of our legitimate business interest.
7. Who we share your data with
7.1 We may have to share your personal data with the parties set out below for the purposes outlined in 6. How and why we use your personal data.
Examples of the kind of third parties we work with are:
• IT companies who support our website and other business systems
• Operational companies such as delivery couriers
• Manufacturers of made to order products
• Data insight companies to ensure your details are up to date and accurate
• We may also share certain limited information with companies who assist us with other services, for example, in analysing our customer data in order to better understand, profile and monitor customer patterns so we can consistently improve our products and services and understand what may be of interest to you and other customers. They will only be allowed to use your information in the way in which we instruct them and as permitted by the Data Protection Act or the GDPR. To opt out of having your data used in this way, please email email@example.com
• For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. In order to protect your privacy we will:
• Only provide the information necessary to perform their specific services
• Only use their data for the exact purpose we specify in our contract with them
• Work closely with them to ensure their privacy is respected and protected at all times
8. International transfers
8.1 We will only transfer your data outside of the EEA in compliance with data protection laws and provided appropriate or suitable safeguards are in place to protect your data, these being either standard contractual clauses, binding corporate rules or in the case of transfers to the USA, a Privacy Shield Certification. Please contact us if you would like details of the appropriate safeguards used if we transfer your data in such circumstances
9. How we protect your data
9.1 The security of your personal data is very important to us and we are committed to treating it with the utmost care, taking all appropriate steps to protect it. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. Access to your personal data is password-protected, and sensitive data (such as payment card information) is secured and tokenised to ensure it is protected. We secure access to all transactional areas of our websites and apps using 'https' technology. We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
10. How long we keep your data for
10.1 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. For example, if your order included a product guarantee, the associated personal data will be kept until the end of the guarantee period. At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
11. Your rights over your personal data
11.1 Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You have the right to:
• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
• You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
• You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
If you wish to exercise any of the rights set out above, please contact Data Privacy LUMA 98 Church Road Barnes London SW13 0DQ or email firstname.lastname@example.org To ask for your information to be amended, please contact our Customer Services team by email email@example.com . To opt out from email marketing please click on the unsubscribe link featured at the bottom of each marketing email we send. If we choose not to action your request we will explain to you the reasons for our refusal. No fee usually required You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you: We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. Time limit to respond We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.