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Privacy Policy

 

We are committed to respecting and protecting your privacy. This policy will inform you as to how we look after your personal data when you visit our website or use our app.

 

“We” “Us” or “LUX Rewards” is the controller and responsible for your personal data under this privacy policy.

 

We are registered with the Information Commissioner's Office and have a registered Data Protection Officer. If you have any questions about this policy, please reach out to our team via email at info@luxrewards.co.uk. 

 

Our website and app are not intended for children and we do not knowingly collect data relating to children.

 

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.


 

 

1. Information about us

  • 1.1. In this privacy policy, the following definitions are used:

    • Data: Collectively all information and any other kind of personal data that you submit to LUX REWARDS LTD. via the Website or Mobile application. This definition incorporates, where applicable, the definitions provided in the Data Protection Act 1998;

    • LUX REWARDS LTD., or us or we: a company incorporated in England and Wales with registered number 09914393 whose registered office is at 5 Collins Buildings, High Street, Saltford, Bristol, England, BS31 3EH;

    • User or you: Any person that accesses the Website and is not either (i) employed by LUX REWARDS LTD. and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to LUX REWARDS LTD. and accessing the Website in connection with the provision of such services;

    • Website: The website that you are currently using, www.luxrewards.co.uk, and any sub-domains of this site unless expressly excluded by their own terms and conditions.

    • Mobile application., or app: The mobile application developed by and for LUX Rewards Ltd. as available on Apple’s App store and Google play store.

    • Partner venue: A restaurant, bar or nightclub who is partnered with LUX, offering points to LUX users from their total bill amounts. Featured on the mobile application or website. The owners have access to a management portal.

  • 1.2. For avoidance of doubt, LUX Rewards’ online services include both a website and mobile application, referred together throughout as “website”. This includes attempts to access LUX Rewards’ services via other digital channels including, but not limited to, mobile tablets and other devices.

  • 1.3. In this privacy policy, unless the context requires a different interpretation:

    • 1.3.1. The singular includes the plural and vice versa;

    • 1.3.2. References to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;

    • 1.3.3. A reference to a person includes firms, companies, government entities, trusts and partnerships;

    • 1.3.4. "Including" is understood to mean "including without limitation";

    • 1.3.5. Reference to any statutory provision includes any modification or amendment of it;

    • 1.3.6. The headings and sub-headings do not form part of this privacy policy.

 

2. Third-Party Links 

  • 2.1. This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit. 

3. Data collected

  • 3.1. We may collect the following Data, which includes personal Data, from you:

  • Name

  • Email address

  • Favourited rewards

  • Claimed rewards

  • Location (if permission is given)

  • Credit or debit card information will be gathered securely by Fidel (a third party as listed in section 5). LUX REWARDS LTD. will only receive a token that we can associate with this card, so no card details are held within the LUX REWARDS LTD. database or systems.

  • Transactional information on any of your registered debit or credit cards, when used in one of LUX’s Partner Venues. This includes date, time and location of transaction and amount spent. The only transactional data that LUX REWARDS LTD. will have access to, are transactions made in LUX’s Partner Venues. To clarify, we cannot take payment and we cannot access your bank account. 

  • Technical data may also be collected includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website

  • Profile Data includes your name 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.

 

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

 

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

 

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

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4. How do we collect your Data

 

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

    • apply for our products or services;

    • create an account or use the services our website or app;

    • subscribe to our service or publications;

    • register any of your debit or credit cards to use our service;

    • use a registered card to pay in our Partner Venues;

    • spend or claim rewards;

    • request marketing to be sent to you;

    • enter a competition, promotion or survey; or

    • give us feedback or contact us. 

  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs] and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy (see below) for further details.

  • Third parties or publicly available sources. We will receive personal data about you from various third parties such as card issuers who have partnered with us (whose privacy policy you should also read):

Technical Data from the following parties:

(a)analytics providers such as Google based outside the EU

 

Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.



 

5.  Our use of Data

 

  • 5.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

    • Where we need to perform the contract we are about to enter into or have entered into with you (e.g. allow you to use our app to collect and spend rewards points).

    • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

    • Where we need to comply with a legal obligation.

  • 5.2 Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:

    • 5.2.1.1. Internal record keeping;

    • 5.2.2. Improvement of our products/services;

    • 5.2.3. To personalise user's experience and to allow us to deliver the type of content and product offerings in which you are most interested;

    • 5.2.4. Contact for market research purposes which may be done using email or mail. Such information may be used to customise or update the Website; in each case, in accordance with this privacy policy.

    • Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

 

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

 

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.


 

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
 

 

5.3 Disclosures of your Data 

 

  • 5.3.1 We may share your Data with our Partner Venues on the LUX Rewards platform. Data may be disclosed to selected partners when users have made transactions or/and claimed points at specific venues using registered cards. If a User has not transacted/claimed in a Partner Venue then no data will be shared with said Partner Venue.

  • 5.3.2. LUX REWARDS LTD. may, from time to time, employ the services of other parties for dealing with certain processes necessary for the operation of the Website and mobile application (such as IT administrators). The providers of such services do not have access to certain personal Data provided by Users of this Website.

  • 5.3.3. We use the following third party(s) to conduct business with legitimate interest:

  • 5.4. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others' rights, property, or safety.

  • 5.5. non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

 

We may also share your Data with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

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8. Controlling use of your Data

  • 8.1. Wherever you are required to submit Data, you will be given options to restrict our use of that Data. This may include the following:

    • 8.1.1. Use of Data for direct marketing purposes; and

    • 8.1.2. Sharing Data with third parties.

  • 8.2. Restrictions to the data can be managed in the settings section of the mobile application and upon request to the support team.

 

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9. Functionality of the Website and mobile application

  • 9.1. To use all features and functions available on the Website, you may be required to submit certain Data.

  • 9.2. We use cookies on our website to help compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. Cookies allow us to keep track of advertisements, compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.

 

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10. Accessing your own Data

  • 10.1. You have the right to ask for a copy of any of your personal Data held by LUX REWARDS LTD. (where such Data is held in accordance with this privacy policy).

  • 10.2. Where data is inaccurate, the individual concerned has a right to apply to rectify, block, erase or destroy the inaccurate information. Please contact LUX Rewards at info@luxrewards.co.uk to rectify this issue.

 

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11. Security and retention

  • 11.1. Data security is of great importance to LUX REWARDS LTD. and to protect your Data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure Data collected via this Website.

  • 11.2 The mobile application is hosted and stored with Amazon Web Services in accordance with their privacy policy here.

  • 11.3. If password access is required for certain parts of the Website, you are responsible for keeping this password confidential.

  • 11.4. We endeavour to do our best to protect your personal Data. However, transmission of information over the internet is not entirely secure and is done at your own risk. We cannot ensure the security of your Data transmitted to the Website.

  • 11.5 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 or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

  • 11.6 To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

  • 11.7 By law we have to keep basic information about our customers for six years after they cease being customers for tax purposes. 

 

In some circumstances you can ask us to delete your data. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

 

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12. General

  • 12.1. You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.

  • 12.2. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.

  • 12.3. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

  • 12.4. This privacy policy is governed by and interpreted according to English law. All disputes arising under this privacy policy are subject to the exclusive jurisdiction of the English courts.

 

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13. Your rights in connection with personal information

Under certain circumstances, by law, you have the right to:

  • 13.1. Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a confirmation from us as to whether we process any of your personal information or not, and if this is the case, to receive a copy of such personal information and to check that we are lawfully processing it. 

  • 13.2. 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.

  • 13.3. Request erasure of your personal information (often referred to as “the right to be forgotten”). 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).

  • 13.4. 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.  

  • 13.5. 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, or if we no longer need your data for our legitimate interests but we need to hold some of it for the purpose of legal proceedings.

  • 13.6. Request the transfer of your personal information to another party.

 

If you would like to exercise any of the above rights, please email us.

  • let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill). This is to allow us to verify your identity and prevent disclosure to unauthorised third parties; and

  • let us know the details of your request, for example by specifying the personal data you want to access, the information that is incorrect and the information with which it should be replaced.

 

Please note that if you request erasure, object to our processing of your personal data or request the restriction of our processing of your personal data we may not be able to provide our services and we may need to deactivate your account on our Website.  

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You also have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at: info@luxrewards.co.uk. You can always unsubscribe from our email communications at any time by following the unsubscribe link in our email communications, or by updating your email preferences on your profile on our Website.

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14. Changes to this privacy policy

  • 14.1. LUX REWARDS LTD. reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations.

  • 14.2. You may contact LUX REWARDS LTD. by email at info@luxrewards.co.uk


 

15. Contact us or the ICO

If you have any concerns or complaints about our privacy activities, you can contact us on info@luxrewards.co.uk. You can also contact the Information Commissioner’s Office on 0303 123 1113.

For more details about your rights under the Act, the rules we have to adhere to in collecting and storing your information, and how you can check your data records, please visit https://www.gov.uk/data-protection/the-data-protection-act.

 

 

Cookie Policy

 

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

 

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

  • Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

  • Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

  • Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

  • Social Media cookies. These cookies work together with social media plug-ins. For example, when we embed photos, video and other content from social media websites, the embedded pages contain cookies from these websites. Similarly, if you choose to share our content on social media, a cookie may be set by the service you have chosen to share content through.

  • Please note that the following third parties may also use cookies, over which we have no control. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third party cookies are likely to be analytical cookies or performance cookies or targeting cookies:

  • Google and Facebook

  • You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

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