Digital Luxury, t/a Informed Luxury is committed to protecting our customer privacy and takes its responsibility regarding the security of customer information very seriously. We will be clear and transparent about the information we are collecting and what we will do with that information.
This Policy sets out the following:
- What personal data we collect and process about you in connection with your relationship with us as a customer and through your use of our website, mobile applications and online services;
- Where we obtain the data from;
- What we do with that data;
- How we store the data;
- Who we transfer/disclose that data to;
- How we deal with your data protection rights;
- And how we comply with the data protection rules.
- All personal data is collected and processed in accordance with EU data protection laws.
“Digital Luxury Limited” (referred to as “we”, “us”, “our” or “Informed Luxury” in this policy) in this policy primarily refers to Digital Luxury Limited the main operating company of the Informed Luxury, and, where appropriate, to other companies in the Digital Luxury group or other entities over which Informed Luxury exercises management control. Informed Luxury is the “data controller” of all personal information that is collected and used about Informed Luxury subscribers and customers for the purposes of [the UK Data Protection Act 2018]. Digital Luxury Limited is registered in Scotland with registration number SC571786 and registered offices at 13-15 Morningside Drive, Edinburgh, EH10 5LZ
WHAT PERSONAL DATA WE COLLECT
Personal data means any information relating to you which allows us to identify you, such as your name, contact details, payment details and information about your access to our website. We may collect personal data from you when you create an Informed Luxury Account, use our website and/or App, participate in a survey or competition or when you contact us.
Specifically, we may collect the following categories of information:
- Name, home address, e-mail address, telephone number, credit/debit card or other payment details;
- Information about your booking enquiry for our trusted partners’ products and services;
- Information about your use of our website and/or App;
- The communications you exchange with us or direct to us via emails and social media.
WHAT DO WE USE YOUR PERSONAL DATA FOR, WHY AND FOR HOW LONG
Your data may be used for the following purposes:
- Providing products and services you have enquired about from our trusted partners.
- Contacting you in the event of winning a competition; request to contact; we send you communications about the services you have asked for and any changes to such services. These communications are not made for marketing purposes and cannot be opted-out of;
- Credit or other payment card verification/screening: we use your payment information for accounting, billing and audit purposes and to detect and / or prevent any fraudulent activities;
- Customer Services communications: we use your data to manage our relationship with you as our customer and to improve our services and enhance your experience with us;
- Provide tailored services: we use your data to provide information we believe is of interest to you to personalise the services we offer to you, such as special offers;
- Marketing: from time to time we will contact you with information regarding offers and updates via e-communications. You will have the choice to opt in or opt outwhen receiving such communications. You will also be given the opportunity on every e-communication that we send you to indicate that you no longer wish to receive our direct marketing material.
We will only process your personal data where we have a legal basis to do so. The legal basis will depend on the reasons we have collected and need to use your personal data for.
We may also process your personal data for one or more of the following:
- You have consented to us using your personal data (e.g. for marketing related uses);
- It is in our legitimate interests in operating as a digital marketing platform (e.g. for administrative purposes).
Only children aged 18 or over can provide their own consent. For children under this age, consent of the children’s’ parents or legal guardians is required.
We will not retain your data for longer than is necessary to fulfil the purpose it is being processed for. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the purposes for which we process it and whether we can achieve those purposes through other means. When you ‘Opt Out’ from receiving our marketing information we will securely delete or destroy your data.
Security of your personal data
We follow strict security procedures in the storage and disclosure of your personal data, and to protect it against accidental loss, destruction or damage. The data you provide to us is protected using SSL (Secure Socket Layer) technology. SSL is the industry standard method of encrypting personal information and credit card details so that they can be securely transferred over the Internet.
When the payment gateway is introduced onto informedluxury.com, all payment details are transmitted over SSL across dedicated network infrastructure (Multiprotocol Label Switching-MPLS) and stored in compliance with Payment Card Industry Data Security Standards (PCI DSS).
Sharing your personal data
- Partners and third parties required to deliver any services requested, eg property owners
- Trusted service providers we are using to run our business such as cloud service and e-mail marketing service providers assisting our marketing team with running customer surveys and providing targeted marketing campaigns;
- When our payment gateway is introduced on informedluxury.com, credit and debit card companies which facilitate your payments to us, and anti-fraud screening, which may need information about your method of payment to process payment or ensure the security of your payment transaction;
- Legal and other professional advisers, law courts and law enforcement bodies in all countries we operate in in order to enforce our legal rights in relation to our contract with you;
- Our trusted third party ancillary partners (identified on our website) who offer luxury related products and services on our website: If you choose to purchase products or services offered on our websites by third parties such as you may be a customer of both Informedluxury.com and these third parties, and we and our partners may collect and share information about you, such as your contact details. We are not responsible for third parties’ use of your personal data where such use is permitted for their own purposes. Please consult their privacy policies for further information.
MY INFORMED LUXURY
We understand the importance of taking extra precautions to protect the privacy and safety of children. Accordingly, children under 18 will not be permitted to open register an account with Informed Luxury. We will delete any Informed Luxury account created by a child under 18 as soon as we are made aware of it.
You will have the option to stay signed-in into your Informed Luxury account by checking the “keep me logged in” box. This option will only apply to the computer / device and the browser that you’re using when you select the box. If you do not wish to stay signed on a particular browser, simply sign out of my Informed Luxury account on that browser.
When our use of your personal data is based on your consent, you have the option to withdraw your consent to our processing and delete your personal data at any time by clicking on the “delete” buttons provided in your Informed Luxury account.
We keep your personal information contained in your Informed Luxury account for as long as you hold the account. You may delete your Informed Luxury account by clicking on the “delete” button provided in the Settings of your account. Please note that general retention periods apply to any personal data we collected to enter into a contract with you or to perform that contract or because we have a legal obligation to process it.
Cookies and site tracking
Cookies are small text files that are transferred to your computer’s hard drive through your web browser to enable us to recognise your browser and help us to track visitors to our site; thus enabling us to understand better the products and services that will be most suitable to you. A cookie contains your contact information and information to allow us to identify your computer when you travel around our site for the purpose of helping you accomplish your reservation. Most Web browsers automatically accept cookies, but, if you wish, you can change these browser settings by accepting, rejecting and deleting cookies. The “help” portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you choose to change these settings, you may find that certain functions and features will not work as intended. The cookies we use do not detect any information stored on your computers.
For more information about cookies and how to stop cookies being installed visit the following website: http://www.allaboutcookies.org.
We use tracking software to monitor customer traffic patterns and site usage to help us develop the design and layout of the websites. This software does not enable us to capture any personal information.
Data Protection Officer
We have appointed a Data Protection Officer (“DPO”) to oversee compliance with this policy. If you have any questions about this policy or how we handle your personal information, please contact the DPO at DPO@informedluxury.com. You have the right to make a complaint at any time to a supervisory authority. The UK Data Protection Commissioner is the lead data protection supervisory authority for Digital Informed Luxury as a UK data controller.
Your Data Protection Rights
Under certain circumstances, by law you have the right to:
- Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding/using it.
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Object to automated decision-making including profiling, that is not to be subject of any automated decision-making by us using your personal information or profiling of you.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request transfer of your personal information in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format.
- Withdraw consent. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
If you want to exercise any of these rights, then please email our DPO at DPO@informedluxury.com or contact our DPO by post at Digital Informed Luxury, 13-15 Morningside Drive, Edinburgh, EH10 5LZ
You will not have to pay a fee to access your personal information (or to exercise any of the other rights).
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.