Privacy Policy (UK) June 2023
LADY GENI LTD
trading as Lady Geni
incorporated under the Companies Act 2006 as a private company, limited by shares with its registered office in England and Wales.
Company Number 149677
Welcome to LADY GENI’s privacy policy.
LADY GENI respects your privacy and is committed to protecting your personal data. This privacy policy will inform you how we collect, process and look after your personal data when you visit our website and engage our services and tell you about your privacy rights and how the law protects you.
When you engage our services or take part in a competition, we may collect personal information such as your name, email address and other contact information.
LADY GENI acts as the controller of your data and Sonja Sarantis is appointed as our data protection officer (DPO) and is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Contact name: Sonja Sarantis
Email address: ask@ladygeni.com
Postal address: 14 Rougemont Avenue, Morden, Surrey, SM4 5PZ
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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.
- Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated in June 2023. It is important that the personal data we hold about you is accurate and current so that we can provide the best services to you so please keep us informed if your personal data changes during your relationship with us.
- The data we collect about you
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 as follows:
- Identity Data includes first name, maiden name, last name, email address, username or similar identifier and your title.
- Contact Data includes billing address, postal address, email address and telephone numbers.
- Financial Data includes bank account and PayPal details.
- Transaction Data includes details about payments from you and other details of services you have purchased from us.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Special Categories of Personal Data includes details about your race or ethnicity and genetic data which we may process or use in order to provide our services to you.
- How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- complete an on-line enquiry form;
- apply for our services via phone or email;
- subscribe to our service or publications;
- request information to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
- How we use your personal data
We will only use your personal data when the law allows us to – that is where we have a Lawful Basis to do so. Most commonly, we will use your personal data in the following circumstances:
- Performance of Contract or services we have agreed with you.
- Where we need to Comply with a legal obligation.
- Where we have a Legitimate Interest to do so.
Generally, we do not rely on consent as a legal basis for processing your personal data (we set out the Lawful Basis on which we do rely in the table below). You have the right to withdraw consent to marketing at any time by contacting us.
- Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our Legitimate Interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of Legitimate Interest |
|
To register you as a new customer |
(a) Identity (b) Contact |
Performance of Contract/our services with you |
|
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) General Communications |
(a) Performance of Contract/our services with you (b) Necessary for our Legitimate Interests (to recover debts due to us) |
|
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of Contract/our services with you (b) Necessary to comply with a legal obligation (c) Necessary for our Legitimate Interests (to keep our records updated and to study how customers use our products/services) |
|
To enable you to partake in a prize draw, competition or complete a survey |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of Contract with you (b) Necessary for our Legitimate Interests (to study how customers use our products/services, to develop them and grow our business) |
|
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity (b) Contact (c) Technical |
(a) Necessary for our Legitimate Interests such as for running our business (b) Necessary to comply with a legal obligation |
|
To make suggestions and recommendations to you about goods or services that may be of interest to you |
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications |
Necessary for our Legitimate Interests (to develop our products/services and grow our business) |
- Marketing, Opting Out and Promotional Offers from us
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can ask us or third parties to stop sending you marketing messages at any time contacting us at any time – see the “Contact us” page.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).
- International transfers
We may transfer your Identity, Contact, Financial, Transaction, Profile, and Special Categories of Personal Data outside the UK in limited circumstances and only where this is necessary in order for us to provide our services to you/Performance of Contract.
- Data security
We have appropriate security measures to prevent your personal data from being accidentally lost and we limit access to your personal data only 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. We have also 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.
- Data retention – how long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
- Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data, such as to request:
- access to your personal data;
- correction of your personal data;
- erasure of your personal data;
- restriction of processing your personal data;
- the right to withdraw consent; and
- object to processing of your personal data;
If you wish to exercise any of the rights set out above, please contact us – see the “Contact Us” page. No fee is usually required and 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.
- 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 could 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.
Glossary
LAWFUL BASIS
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 obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
YOUR LEGAL RIGHTS
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:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- 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.
- 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 in Performance of 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.