Privacy Policy

What This Policy Applies To

This privacy policy relates to your use of our website only.

Throughout our website, we may link to other websites owned and operated by certain trusted third parties to make additional products and services available to you. Those other third-party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third-party websites, please consult their privacy policies as appropriate.

Personal Data We Collect About You

The personal data we collect about you depends on the particular activities carried out through our website. We will collect and use the following personal data about you:

• Your name, address, and contact information, including email address and telephone number, and company details
• Information to check and verify your identity, e.g., date of birth
• Your gender, if you choose to give this to us
• Location data, if you choose to give this to us
• Your billing information, transaction and payment card or other payment method information
• Bank account and payment details
• Details of any information, feedback, or other matters you give us by phone, email, post, or via social media
• Your account details, such as username and login details
• Your activities on and use of our website
• Information about the services we provide to you
• Your contact history, purchase history, and saved items
• Information about how you use our website and technology systems
• Your responses to surveys, competitions, and promotions

If you do not provide personal data we ask for where it is indicated to be ‘required’ at the point of collection, it may delay or prevent us from providing products and services to you.

We collect and use this personal data for the purposes described in the section ‘How and Why We Use Your Personal Data’ below.

How Your Personal Data Is Collected

We collect personal data from you:

• Directly, when you enter or send us information, such as when you register with us, contact us (including via email), send us feedback, or purchase products or services via our website
• Indirectly, such as your browsing activity while on our website; we will usually collect information indirectly using the technologies explained in the section on ‘Cookies and Other Tracking Technologies’ below

How and Why We Use Your Personal Data

Under data protection law, we can only use your personal data if we have a proper reason, e.g.,:

• Where you have given consent
• To comply with our legal and regulatory obligations
• For the performance of a contract with you or to take steps at your request before entering into a contract
• For our legitimate interests or those of a third party

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use your personal data for and why.

Marketing

We may use your personal data to send you updates (by email, text message, telephone, or post) about our products and/or services, including exclusive offers, promotions, or new products and/or services.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and Why We Use Your Personal Data’). This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by:

• Contacting us at customerservice@lulabay.co.uk;
• Using the ‘unsubscribe’ link in emails or the ‘STOP’ number in texts

We may ask you to confirm or update your marketing preferences if you ask us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.

For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at www.networkadvertising.org. You can opt out of targeted advertising by using the links below:

• Facebook
• Google
• Bing

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: www.optout.aboutads.info.

We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.

For more information on your rights to object at any time to your personal data being used for marketing purposes, see ‘Your Rights’ below.

Who We Share Your Personal Data With

We routinely share personal data with:

• Third parties we use to help deliver our products and/or services to you, e.g., payment service providers, warehouses, and delivery companies
• Other third parties we use to help us run our business, e.g., marketing agencies or website hosts and website analytics providers
• Shopify to power our online store—you can read more about how Shopify uses your Personal Information here.

We or the third parties mentioned above may occasionally also need to share personal data with:

• External auditors, e.g., in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations
• Professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
• Law enforcement agencies, courts, tribunals, and regulatory bodies to comply with our legal and regulatory obligations
• Other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering, or in the event of our insolvency—usually, information will be anonymised but this may not always be possible; however, the recipient of the information will be bound by confidentiality obligations

If you would like more information about who we share our data with and why, please contact us (see ‘How to Contact Us’ below).

Your Rights

You generally have the following rights, which you can usually exercise free of charge:

• Access to a copy of your personal data: The right to be provided with a copy of your personal data
• Correction (also known as rectification): The right to require us to correct any mistakes in your personal data
• Erasure (also known as the right to be forgotten): The right to require us to delete your personal data—in certain situations
• Restriction of use: The right to require us to restrict use of your personal data in certain circumstances, e.g., if you contest the accuracy of the data
• Data portability: The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
• To object to use: The right to object:
  • At any time to your personal data being used for direct marketing (including profiling)
  • In certain other situations to our continued use of your personal data, e.g., where we use your personal data for our legitimate interests.
• Not to be subject to decisions without human involvement: The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

We do not make any such decisions based on data collected by our website.

For further information on each of those rights, including the circumstances in which they apply and circumstances in which they do not apply, please contact us (see ‘How to Contact Us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.

If you would like to exercise any of those rights, please email, call, or write to us—see below: How to Contact Us. When contacting us please:

• Provide enough information to identify yourself and any additional identity information we may reasonably request from you, and
• Let us know what right you want to exercise and the information to which your request relates

Keeping Your Personal Data Secure

We have appropriate security measures to prevent personal data from being accidentally lost or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to Complain

Please contact us if you have any query or concern about our use of your information (see below ‘How to Contact Us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner:

• The UK’s Information Commissioner may be contacted at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.

Changes to This Privacy Policy

We may change this privacy policy from time to time. When we make significant changes, we will take steps to inform you, for example, via this website or by email if we hold your email address.

How to Contact Us

You can contact us by post, email, or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law, or to make a complaint.

Our Contact Details

customerservice@lulabay.co.uk