PRIVACY POLICY

WHAT DOES THIS POLICY COVER?

This policy describes how Luxburry Strategies Inc.  (“we” or “us”) will make use of your data when you interact with us through our website, currently located at www.luxburrystrategies.com.

It also describes your data protection rights, including the right to object to some of the processing that we carry out. More information about your rights and how to exercise them is in the “What rights do I have?” section below. Our website is not intended for or directed at anyone under 18. We do not intentionally or knowingly collect or maintain personal data relating to anyone under 18. 

SUMMARY OF HOW WE USE YOUR DATA

  • We use your personal data to provide services to you for administrative purposes, personalize the content you see on our website, identify your location, and improve your services.
  • Where we rely on your consent, such as for processing your data to provide personalized services to you or sending direct marketing about our relevant products and services, or other products and services provided by us, you can withdraw this consent at any time.
  • Respond to your request for information and provide more effective and efficient customer service.
  • Establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others.
  • We will only use your personal data for the purposes 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 explain how the new purpose’s processing is consistent with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and 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 rules stated in this privacy policy, where this is required or permitted by law.

WHAT INFORMATION DO WE COLLECT?

We collect and process personal data about you when you interact with our website or if you interact with us in person. We may collect, use, store, and transfer different kinds of personal data about you, which we have grouped together as follows: 

  • Identity data include first name, maiden name, last name, username, or similar identifier.
  • Contact Data such as email address and telephone numbers.
  • Technical Data has an IP address, 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 our website.
  • Profile Data such as your username and password, preferences, feedback, and survey responses.
  • Usage Data such as information about how you use our website and services.
  • Marketing and Communications Data include your preferences in receiving marketing from us and our third parties and your communication preferences.

WHAT INFORMATION DO WE RECEIVE FROM A THIRD PARTY?

Sometimes, we receive information about you from third parties. 

HOW DO WE USE THIS INFORMATION, AND WHAT IS THE LEGAL BASIS FOR THIS USE?

As required to conduct our business and pursue our legitimate interests, we process this personal data for the following purposes:

  • Communicating with you
  • Sharing your data as required for the service from time to time
  • To monitor your use of our website and online services, and use your information to help us monitor, improve, and protect our content, services, and website to provide you with the most user-friendly navigation experience (both online and offline)
  • To personalize our website (including any future websites), products, or services for you
  • We use the information you provide to investigate any complaints received from you or from others about our website or our products or services
  • We will use data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation) 

Where you give us consent:

  • We may send you direct marketing concerning our relevant services or other services provided by us or our affiliates.
  • We place cookies and use similar technologies under our Cookies Policy and the information provided to you when those technologies are used.
  • On other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time, such as to prepare user recommendations.
  • For legal requirements, specific requests by the government, or the need for law enforcement’s investigation.
  • Withdrawing consent or otherwise objecting to direct marketing

Where we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those above. Sometimes, we can send you direct marketing without your consent, where we rely on our legitimate interests. You have the right to opt out of direct marketing. You can do this by contacting us at info@luxburrystrategies.com.

WHO WILL WE SHARE THIS DATA WITH, WHEN, AND WHERE?

We will keep your data generally confidential, but we may share your data in the following instances:

  • We will share your personal data with third parties where we obtain your consent at that time. We will only share the specific personal data which you authorize us to communicate with such a third party. In such cases, they will be a data controller, and they may have their own privacy terms detailing how they use that personal data.
  • Personal data may be shared with government authorities and/or law enforcement officials if mandated by law or required for the legal protection of our legitimate interests in compliance with applicable laws. 
  • Personal data may also be shared with third-party service providers, who will process it on our behalf for the purposes identified above. Such third parties include (without limitation) website hosting providers, maintenance, call center operation, and identity checking.
  • Personal data may also be shared with professional advisers acting as processors or joint controllers, including lawyers, bankers, auditors, and insurers who provide us with consultancy, banking, legal, insurance, and accounting services.
  • Suppose our service is sold or integrated with another business. In that case, your details will be disclosed to our advisers and any prospective purchaser’s adviser and passed to the new supplier of such services.
  • If you are accessing our website from within the European Economic Area (“EEA”), your data might be accessed, collected, and/or stored on servers outside the EEA.

WHAT RIGHTS DO I HAVE?

You have the right to ask us for a copy of your personal data; to correct, delete, or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine-readable format. In some cases where you have requested that your personal data be deleted, we may still have to keep this data as the removal of such data will impact other data. In such cases, you can request that such data be anonymized.

In addition, you can object to processing your personal data in some circumstances where we don’t have to process the data to meet a contractual or another legal requirement or where we are using the data for direct marketing.

These rights may be limited, for example, if fulfilling your request would reveal personal data about another person or if you ask us to delete information that we are required by law to keep or where we have compelling legitimate interests in keeping.

To exercise any of these rights, you can get in touch with us using the details below.

The provision of certain information may be mandatory for the provision of certain services. If the relevant data is not provided, then we may not be able to provide you with certain services. All other provision of your information is optional. However, note that failure to provide the optional data means that we will not be able to send you communications about the goods and services that may be of interest to you, nor personalize how our content is presented to you.

HOW DO I GET IN TOUCH WITH YOU?

We hope we can satisfy queries you may have about how we process your data. If you have any concerns about how we process your data or want to opt-out of direct marketing, you can get in touch by emailing us at info@luxburrystrategies.com.

HOW LONG WILL YOU RETAIN MY DATA?

We will only keep your content for as long as is reasonably required for the purpose(s) for which it was submitted. We may retain your personal data for a more extended period in the event of a complaint or if we reasonably believe there is a prospect of litigation for our relationship with you.

Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a reasonable period after this (to allow us to implement your requests). We also keep a record that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in the future.