APPLICATION OF THIS STATEMENT
- The application of this policy
- The kinds of information we may collect about you, how we collect it and how we use it
- How we may disclose information we hold about you
- How you can access the information we hold about you
- How you can update your information
- The security of your personal information
- Online (website) security
- Children’s privacy
- How to contact us
YOUR ACKNOWLEDGEMENT OF OUR PRIVACY STATEMENT
By using this website, or when you otherwise interact with us and use our services, you acknowledge that you’ve read and understood this privacy statement and you are consenting to the practices described in this statement.
For the purpose of the Data Protection Act 1998 (the “Act”), the data controller is LifeStyles (trading as SxWell UK) of 6th floor, 60 Gracechurch Street, London EC3V 0HR, United Kingdom.
Our website contains links to non-LifeStyles websites. LifeStyles is not responsible for the privacy policies of third party websites and recommends you review the privacy policies of each site you visit.
THE KIND OF INFORMATION WE COLLECT AND HOLD
We will collect and process the following data about you:
- Information you give us
This is information about you that you give us. It includes information you provide when you register to use our website, subscribe to our service, search for a product, place an order on our website, participate in discussion boards or other social media functions on our website, enter a competition, promotion or survey and when you report a problem with our website. The information you give us could include your name and contact details including address, email address, phone number or mobile telephone number. It may also include certain demographic data such as your date of birth and business information such as your occupation and how you use our products and services. Sometimes we may also collect some financial information such as credit card or bank account numbers when processing payments.
- Information we collect about you.
With regard to each of your visits to our website we will automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.
- Information we receive from other sources.
This is information we receive about you if you use any of the other websites we operate or the other services we provide. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
HOW WE COLLECT YOUR INFORMATION
We may collect personal information directly from you (either in hard copy or electronically) when you:
- Fill in an application form or agreement for one of our products or services; enter a competition,
- Fill in a request form for a newsletter subscription or electronic mailing list;
- Purchase a product or require a service from us;
- Request a sample from us;
- Deal with us over the telephone;
- Email us;
- Create an account with us; or you
- Ask us to contact you after visiting our website or attending a trade show or other event.
- We may also collect your personal information from third parties in a number of ways, including:
- From our related entities, business partners, credit reporting bodies, your authorised representatives;
- From social media websites and mobile platforms;
- From third party list providers;
- From publicly available sources of information;
- From records of how you use our products and services;
- From the third parties we list in the section of this statement with the heading ‘when we disclose your information’.
We will only collect your information by lawful and fair means and not in an unreasonably intrusive way.
If you choose not to provide certain information about yourself, you should be aware that we may not be able to provide you with the services you need or the quality of service we would otherwise ensure you receive.
We may also collect information from you passively online. Please refer to the heading ‘Online security and privacy’.
ONLINE SECURITY AND PRIVACY
In order to properly maintain this website, LifeStyles (like all major sites on the Internet) passively tracks navigational information, for example through use of session cookies. This information tells us about the number and frequency of visitors to our website but it does not tell us the identity of those visitors. Therefore, we do not use these technologies to collect or store personal information.
This information helps us improve our service by understanding what our customers use and don’t use. It also helps us identify if there are problems with our service that require fixing. Generally, we do not require you to provide personally identifiable information to visit and use our website. However, in order to participate in some activities such as online promotions or to access specific sections of our websites, you will need to provide us with particular information. We may ask during those processes for additional information not required to complete your request. Optional information will be noted at the specific area. If you decide not to provide us with the required information, we may be unable to process your request or provide the full range of services available through this website. For example, if you decide not to provide us with your contact information when registering for an online promotion, we will be unable to notify you of subsequent promotional information.
HOW WE USE YOUR INFORMATION
We use the personal information held about you in the following ways:
- Information you give to us. We will use this information:
- to respond to your request (enter you in or notify you about a promotional campaign or to provide you with any request information, products and services, for example) or to carry out our obligations arising from any contracts entered into between you and us;
- To provide you with information about other products and services we offer that are similar to those that you have already purchased or enquired about;
- In order to provide you with this website, and with our products and services, we may share your information with our agents or partners, including but not limited to Shopify and D&S Media Solutions Ltd. For example, when hosting promotions we often work with promotion companies with whom we share your information. These companies collect your information on our behalf, share the information with us, and also retain that information for their own purposes. In addition to sharing your information with our partners and agents, we may also share your information with certain select vendors whose products or services we believe you may find of interest. We may also provide aggregated information about our users to third parties. Where we permit selected third parties to use your data, they will contact you by electronic means only if you have consented to this. If you do not want us to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data. If you do not want us to share your personally identifiable information with unrelated third parties, you may also notify us at any time at firstname.lastname@example.org.
- Information we collect about you. We will use this information:
- To administer the websites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, and to provide you with the product or service you requested, as well as creating better information, products and services by analysing trends. For example, we use this information to determine which areas of this website are more popular, to determine fluctuation of visitor numbers from week to week, to diagnose problems with our server, and to improve your web experience by determining the fastest route for your computer to use in connecting to this website;
- To customise your experience on this website and to improve our website to ensure content is presented in the most effective manner for you and your computer;
- As part of our efforts to keep our website safe and secure;
- To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- To make suggestions and recommendations to you and other users of our website about goods or services that may interest you or them;
- To monitor network use, quality and performance, and to operate, maintain, develop, test and upgrade our systems and infrastructure;
- Information we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
WHEN WE DISCLOSE YOUR INFORMATION
We may disclose your information to third parties who provide services to us, including organisations, agencies and contractors that assist us with the purposes for which we use your information. These services include:
- Marketing activities and promotions;
- Warehousing and logistics services;
- Mailing operations;
- Information technology and network services; and
- Market research.
We may also disclose your information to:
- Analytics and search engine providers that assist us in the improvement and optimisation of our website.
- Credit reference agencies for the purpose of assessing your credit score.
- Your authorised representatives or advisers, or when you ask us to do so;
- Our related entities and business partners;
- To law enforcement and national security agencies and other government and regulatory authorities as required or authorised by law; and
- To third parties who assist us to manage or develop our business and corporate strategies and functions including our corporate risk or funding functions.
We may disclose your personal information to third parties:
- For the purposes of facilitating or implementing a transfer/sale of all or part of our assets or business.
In some cases, we may disclose your information to organisations internationally. For example, we may disclose your information to our service providers in Australia, the United States, an EU member state and other countries in Europe, Thailand, Sri Lanka, India, Malaysia, China and Singapore. This includes staff engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. We will only do so in compliance with all applicable data protection and privacy laws. By submitting your personal data, you agree to this transfer, storing or processing. LifeStyles will take reasonable steps to protect personal information no matter what country it is stored in or transferred to and has procedures in place and agreements with service providers to help ensure this.
We may use the personal information we collect from you to identify particular LifeStyles products, services and promotions which we believe may be of interest to you and to send you surveys and questionnaires, and to assist with the creation and development of new products or services. We may contact you to let you know about these products, services or promotions and how they may benefit you. We will only do this with your prior consent and we will always give you a choice to opt out of receiving such information in future. Direct marketing from LifeStyles will generally take the form of electronic marketing via email. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about products and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you do not want us to use your data in this way please tick the relevant box situated on the form on which we collect your data. Where you are a new customer we will contact you by electronic means only if you have consented to this. If you want us to use your data in this way please tick the relevant box situated on the form on which we collect your data
We may also use your personal information to send you marketing information via post. If you do not want us to use your data in this way please tick the relevant box situated on the form on which we collect your data.
Every directly addressed marketing communication made or sent by us will include a means by which you can unsubscribe or opt out of receiving further marketing information. We will always ensure that our-opt out notices are clear, noticeable and easy to take up with every communication.
HOW WE HOLD YOUR INFORMATION
We may store your information in hard copy or electronic format. In hard copy we may store your information in our offices or storage facilities that we own and operate ourselves, or that are owned and operated by our service providers. We take all reasonable steps to maintain the security of your information and to protect it from unauthorised disclosures.
In electronic format we hold your information in databases with limited and password protected access.
HOW TO ACCESS OR CORRECT YOUR PERSONAL INFORMATION
You have the right to request access to and rectification or erasure of information held about you or to restrict or object to our use of information held about you, and well as the right to obtain and reuse information held about you for your own purposes across different IT environments. Please contact us using the contact details below if:
- You wish to access any of your personal information that we hold;
- You wish to correct or delete any errors in the information we hold;
- You wish to opt out of receiving our newsletter or marketing and/or promotional material from us. Alternatively, you can click ‘unsubscribe’ from an email communication or reply to any email communication with ‘unsubscribe’ in the subject line;
- You do not wish for us to share your personal information with unaffiliated or non-agent third parties.
- You wish to restrict or object to our processing of your personal information.
- If you wish us to transmit your personal information directly to another organisation.
- To protect your privacy, we will only respond to e-mail messages sent from the e-mail account you originally provided to us. Should you elect to have your information deleted, we will also remove your information from our active databases.
Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
HOW LIFESTYLES PROTECTS YOUR INFORMATION / INFORMATION SECURITY
LifeStyles will take all reasonable and practicable steps to ensure that your personal information is properly protected from misuse or loss, unauthorised access, modification or disclosure. We employ appropriate technical, administrative and physical procedures to protect personal information from unauthorised disclosure, loss, misuse or alteration. In addition to technical measures such as firewalls, we have also implemented procedural protection measures such as restricting physical access to your information in our offices, securing that information behind locked cupboards and training and disciplining employees who fail to follow our company’s privacy policies.
We limit access to personal information to individuals with a business need consistent with the reason the information was provided. We keep personal information only for as long as it is required for business purposes or by the law. Once personal information held is no longer required for the purpose for which it was collected it will be de-identified or destroyed securely.
Although we take steps to maintain the security of your information, LifeStyles cannot ensure or warrant the security of any information transmitted to it or from its online products or services, and users do so at their own risk. Once LifeStyles receives any of your personal information, LifeStyles will take reasonable steps to protect that information from misuse and loss and from unauthorised access, modification or disclosure. You should be aware of the many information security risks that exist today and take appropriate care to help safeguard your information.
This website is not intended for, nor do we believe it is appealing to, children under the age of 13. LifeStyles does not knowingly solicit or collect information from children under the age of 13. If LifeStyles learns that it has been provided with information from someone under 13, LifeStyles will destroy that information. We encourage parents to take an active role in ensuring that their children do not send information about themselves anywhere on the Internet unknowingly, and suggest that they use software tools or online services to ensure a safe Internet experience for their children.
REPORTING A COMPLAINT
If you think that we have not complied with our privacy obligations you may report a complaint to the contact details below. In the event that you report a privacy breach to us, we will:
- Acknowledge your complaint in writing as soon as practicable or within 7 days;
- Promptly identify and secure the breach to prevent any further breaches;
- Notify appropriate authorities where criminal activity is suspected;
- Assess the nature and severity of the breach including the type of personal information involved and the risk of harm to affected individuals;
- Notify the affected individuals directly if appropriate and where possible;
- Endeavour to investigate and resolve your complaint within 30 days of receiving it. If we need more time, we will notify you.
- Notify relevant authorities if the breach is significant.
- If you are not satisfied with the outcome of your complaint you can refer your complaint to the Information Commissioner’s Office or any other applicable supervisory authority.
HOW YOU CAN CONTACT LIFESTYLES
Any questions or issues can always be addressed to Lifestyles at:
Riverside Business Park – Block I
Boulevard International 55
Tel: +32 2 258 74 00