Privacy policy
Valid from 25.05.2018
1. Introduction
We are committed to safeguarding the privacy of Luxid Group Ltd website visitors and users of the Service that Luxid Group Ltd provides.
This policy applies where we are acting as a data controller with respect to the personal data of Luxid Group Ltd website visitors and users of the Service that Luxid Group Ltd provides; in other words, where we determine the purposes and means of the processing of that personal data.
We use cookies on our website. As far as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.
Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can edit the initially given consent by clearing the browser cache, thus invoking the consent banner for editing the settings.
In this policy, "we", "us" and "our" refer to Luxid Group Ltd.
2. How we use your personal data
2.1. In this Section 2 we have set out:
the general categories of personal data that we may process;
the purposes for which we may process personal data; and
the legal bases of the processing.
We may process the data of the Luxid Group Ltd website visitors and users of the Service that Luxid Group Ltd provides ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency, and pattern of your service use. The source of the usage data is Google Analytics. This usage data may be processed for consent, contractual, legal obligation, vital interests, public task, legitimate interest purposes. The legal basis for this processing is consent OR our legitimate interests, namely monitoring and improving our website and services OR other legal bases listed in this chapter.
We may process your account data ("account data"). The account data may include your name and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases, and communicating with you. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract OR other legal bases listed in chapter 3.2.
We may process your information included in your personal profile on our website ("profile data"). The profile data may include your name, address, telephone number, email address, interests, and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at you request, to enter into such a contract OR other legal bases listed in chapter 3.2.
We may process your personal data that are provided during the use of our services ("service data"). The service data may include any manually entered inputs. The source of the service data is you or your employer. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases, and communicating with you. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract OR other legal bases listed in chapter 3.2.
We may process information that you post for publication on our website or through our services ("publication data"). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent OR our legitimate interests, namely [the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract OR other legal bases listed in chapter 3.2.
We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing, and selling relevant goods and/or services to you. The legal basis for this processing is consent OR other legal bases listed in chapter 3.2.
We may process information relating to our customer relationships, including customer contact information ("customer relationship data"). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications, and promoting our products and services to customers. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships.
We may (but are not doing so currently) process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details, your card details, and the transaction details. The transaction data may be processed for supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.
We may process information that you provide to us for subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
We may process any of your personal data identified in this policy where necessary for the establishment, exercise, or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights, and the legal rights of others.
We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person.
Please do not supply any other person's personal data to us, unless we prompt you to do so.
Read about our Whistleblowing policy.
3. Providing your personal data to others
We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) as far as reasonably necessary for the purposes, and on the legal bases, set out in this policy. Information about our group company can be inquired from the Luxid Group Data Protection Officer (contact information below).
We may disclose your personal data to our insurers and/or professional advisers as far as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise, or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
Financial transactions relating to our website and services are be handled by our financial transaction services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments, and dealing with complaints and queries relating to such payments and refunds.
We may disclose your enquiry data to one or more of selected third-party suppliers of goods and services identified on our website to enabling them to contact you so that they can offer, market, and sell to you relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party's use of your personal data.
Occasionally, we organise events and webinars together with our partner companies. We may disclose your personal data to our partner companies if you have signed up for the event. The legal basis for this processing is consent. Each partner company will act as a data controller in relation to the sign-up data that we supply to it, and upon contacting you, each such partner company will provide you with a copy of its own privacy policy, which will govern that third party's use of your personal data.
In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4. International transfers of your personal data
In this Section, we provide information about the circumstances in which your personal data may be transferred to [countries outside the European Economic Area (EEA)].
We have offices and facilities in Finland, United Kingdom and United States. The European Commission has made an "adequacy decision" with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from https://edps.europa.eu/data-protection/data-protection/reference-library/international-transfers_en.
The hosting facility for our websites and services is situated in Finland. The European Commission has made an "adequacy decision" with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which you can obtain from https://edps.europa.eu/data-protection/data-protection/reference-library/international-transfers_en.
Some cloud-based services that are used in the services we provide are situated in countries outside the European Union, these countries include The United States and United Kingdom (after Brexit). The European Commission has made an "adequacy decision" with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from https://edps.europa.eu/data-protection/data-protection/reference-library/international-transfers_en.
You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
5. Retaining and deleting personal data
This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
We will retain your personal data as follows:
personal data category or categories will be retained for a minimum period of a single session (access to the website), and for a maximum period of 12 months when there are no updated made to the personal data.
In some cases, it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
the period of retention of personal data category will be determined based on last update to the data.
Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person.
6. Amendments
We may update this policy from time to time by publishing a new version on our website.
You should check this page occasionally to ensure you are happy with any changes to this policy.
We may notify you of changes to this policy by email or through a notification on our website or service.
7. Your rights
In this Section, we have summarized the rights that you have under data protection law. Some of the rights are complex, and not all the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
Your principal rights under data protection law are:
the right to access;
the right to rectification;
the right to erasure;
the right to restrict processing;
the right to object to processing;
the right to data portability;
the right to complain to a supervisory authority; and
the right to withdraw consent.
You have the right to confirmation as to whether we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can request your data by emailing the Luxid Group's Data Protection Officer (contact information below).
You have the right to have any inaccurate personal data about you rectified and, considering the purposes of the processing, to have any incomplete personal data about you completed.
In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise, or defense of legal claims.
In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful, but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise, or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise, or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
To the extent that the legal basis for our processing of your personal data is:
consent; or
that the processing is necessary for the performance of a contract to which you are party or to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used, and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
You may exercise any of your rights in relation to your personal data by giving a written notice to the Luxdi Group's Data Protection Officer (contact information below).
8. Our details
This website and services linking to this privacy policy are owned and operated by Luxid Group Ltd.
We are registered in Finland under registration number FI24963805 and our registered office is at Läntinen Rantakatu 3, 20100 Turku, Finland.
Our principal place of business is at Läntinen Rantakatu 3, 20100 Turku, Finland.
You can contact us:
by post, to the postal address given above;
using our website contact form;
by telephone, on the contact number published on our website from 09.00-16.00 EET; or
by email, using the email addresses published on our website.
9. Data protection officer
Our data protection officer's contact details are:
Henrik Lagercrantz
Bulevardi 2-4 A
00120 Helsinki
Finland