LoftyXSound Broadcast Ltd. (“we“,
“us” or “our”) is
committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we
collect from you or that you provide to us will be processed
by us.
It is important that you read this privacy policy together
with any other privacy notice or fair processing notice 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 the other policies and notices and is not
intended to override them.
For the purposes of the Data Protection Act 2018 (the DPA),
the UK GDPR (as section 3(10) of the Data Protection Act
2018, read with section 205(4) of that Act) and all
successor legislation to the DPA and the GDPR (the “Data
Protection Legislation”), the data controller is ES
Broadcast Ltd., a company registered in England and Wales
with company no. 13097814. Within
the EU, the data protection representative is LoftyXSound Broadcast
Hire Spain, SL, a registered company in Spain (CIF nº
ESB88031869), registered at Registro Mercantil de Madrid,
Tomo 37.305, Folio 57, Sección 8ª, Hoja M665219.
1. Information we collect from 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 (known as “anonymous data”).
We may collect, use, store and transfer the following data
about you:
- Information you give us. This is
information about you that you give us by filling in
forms on our website or by corresponding with us by
phone, e-mail or otherwise. It includes information you
provide when you set up an online account, order our
goods or services, make an enquiry, subscribe to our
services or publications, request marketing to be sent
to you, when you report a problem with our site and when
you give us feedback. The information you give us may
include your title, name, address, e-mail address, phone
number, Skype address, job title and company, username
and password, financial and payment information, copies
of your passport or other official identification
documentation.
- Information we collect about you. With
regard to each of your visits to our site we may
automatically collect the following information:
- technical information, including the Internet
protocol (IP) address used to connect your
computer to the Internet, your login
information, browser type and version, time zone
setting, browser plug-in types and versions,
operating system and platform;
- information about your visit, including the full
Uniform Resource Locators (URL), clickstream to,
through and from our site (including date and
time), products you viewed or searched for,
abandoned shopping cart information, page
response times, download errors, length of
visits to certain pages, page interaction
information (such as scrolling, clicks, and
mouse-overs), methods used to browse away from
the page, and any phone number used to call our
customer service number.
- Information we receive from other sources.
We may receive personal data about you from
various third parties including, for example, business
partners, sub-contractors in technical, payment and
delivery services, advertising networks, analytics
providers, search information providers.
We may also collect, use and share aggregated data such as
statistical or demographic data for any purpose. Aggregated
data may be derived from your personal data but is not
considered personal data in law as this data does not
directly or indirectly reveal your identity. 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.
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.
2. Uses made of your information
We will only use your personal data when the law allows us
to. Most commonly, we will use your personal information
- to carry out our obligations arising from any contracts
entered into between you and us or to take steps at your
request before entering into any contracts;
- to comply with any legal obligations to which we are
subject;
- where it is necessary for our or a third party’s
legitimate interests, including for the purposes of
preventing fraud, except where such interests are
overridden by your interests or fundamental rights and
freedoms; or
- where you have provided your express opt-in consent.
3. 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 and/or to set up an online account
|
Identity, contact
details |
(a) Performance of a
contract with you or steps taken at your request
before entering into any contract with you
(b) Necessary to comply with a legal
obligation
|
| To process and deliver
your order including:
(a) Manage payments, fees and charges;
(b) Collect and recover money owed to us;
(c) Provide goods and/or services to you.
|
Identity, contact
details, passport details
|
(a) Performance of a
contract with you
(b) Necessary for our legitimate interests
(to recover debts due to us)
(c) Necessary to comply with a legal
obligation
|
| 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
|
Identity, contact
details, and marketing preferences
|
(a) Performance of a
contract 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 administer and
protect our business and our website (including
troubleshooting, data analysis, testing, system
maintenance, support, reporting and hosting of
data) |
Identity, contact
details and technical data such as IP address
|
(a) Necessary for our
legitimate interests (for running our business,
provision of administration and IT services,
network security, to prevent fraud and in the
context of a business reorganisation or group
restructuring exercise)
(b) Necessary to comply with a legal
obligation
|
| To deliver relevant
website content and advertisements to you and
measure or understand the effectiveness of the
advertising we serve to you |
Identity, contact
details, technical data such as IP address,
marketing preferences |
Necessary for our
legitimate interests (to study how customers use
our products/services, to develop them, to grow
our business and to inform our marketing
strategy) |
| To use data analytics
to improve our website, products/services,
marketing, customer relationships and
experiences |
Technical data such as
IP address |
Necessary for our
legitimate interests (to define types of
customers for our products and services, to keep
our website updated and relevant, to develop our
business and to inform our marketing strategy)
|
| To make suggestions and
recommendations to you about goods or services
that may be of interest to you |
Identity, contact
details, usage data and marketing preferences
|
Necessary for our
legitimate interests (to develop our
products/services and grow our business) |
| To send you updates
about our services and products |
Identity and contact
details |
Consent |
Marketing
We strive to provide you with choices regarding certain
personal data uses, particularly around marketing and
advertising.
We may use your identity, contact details, usage data,
technical data and marketing preferences to form a view on
what we think you may want or need, or what may be of
interest to you. This is how we decide which products,
services and offers may be relevant for you.
You will receive marketing communications from us if you have
requested information from us or purchased products or
services from us or if you provided us with your details
when you entered a competition or registered for a promotion
and, in each case, you have not opted out of receiving that
marketing.
We will get your express opt-in consent before we share your
personal data with any other company for marketing purposes.
You can ask us or third parties to stop sending you marketing
messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, this
will not apply to personal data provided to us as a result
of a product/service purchase, warranty registration,
product/service experience or other transactions.
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.
4. Disclosure of your information
We may have to share your personal information with the third
parties set out below, or any other third parties notified
to you, for the purposes set out in paragraph 3 above:
- Professional advisers including lawyers, bankers,
auditors and insurers based in the UK.
- Regulators and other authorities who require reporting
of processing activities in certain circumstances.
- 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.
- Fraud prevention agencies.
- Any of our group companies.
- Service providers and sub-contractors including delivery
partners, warranty providers and website designers.
- Finance providers.
- Credit reference agencies.
- Google Analytics, our analytics provider.
- Mailchimp, our marketing email platform.
- Paperless Post, our event invitations platform.
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.
5. International transfers
Many of our third parties are based outside the European
Economic Area (“EEA”) so their processing
of your personal data will involve a transfer of data
outside the EEA.
Whenever we transfer your personal data out of the EEA, we
ensure a similar degree of protection is afforded to it by
ensuring at least one of the following safeguards is
implemented:
- Wherever possible, we will only transfer your personal
data to countries that have been deemed to provide an
adequate level of protection for personal data by the
European Commission.
- Where we use certain service providers in countries that
have not been deemed to provide an adequate level of
protection for personal data by the European Commission,
we will only transfer data where we are able to use
specific Standard Contractual Clauses approved by the
European Commission which give personal data the same
protection it has in Europe.
Please contact us if you want further information on the
specific mechanism used by us when transferring your
personal data out of the EEA.
6. Data security
We have put in place appropriate security measures to prevent
your personal data from being accidentally lost, used or
accessed in an unauthorised way, altered or disclosed. In
addition, we limit access to your personal data 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.
However, the transmission of information via the internet and
by email is never completely secure. Although we will do our
best to protect your personal data, we cannot guarantee the
security of your data transmitted to our site or provided to
us by email; any transmission is at your own risk.
We have 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.
7. Retention
We will only retain your personal information for as long as
is necessary to carry out the purpose for which it was
collected, including for the purposes of satisfying any
legal, accounting, or reporting requirements.
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 requirements.
In some circumstances we may 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.
8. Your rights
Under the Data Protection Legislation you may be entitled to
the following rights:
- Where you have provided your consent to the processing
of your personal data for any purpose, you have the
right to withdraw such consent at any time by contacting
us by email to sales@lofyxsounds.com.
- You can ask us to rectify any inaccuracies in the
personal information that we hold about you.
- To request the erasure of personal information that we
hold about you where there is no good reason for us to
continue processing it, where you have successfully
exercised your right to object to processing, where we
may have processed you information unlawfully or where
we are required to erase your personal data to comply
with local law.
- To object to our processing of your personal data where
we are relying on a legitimate interest (or that 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.
- To restrict our processing of your personal data (a) if
you want us to establish the data’s accuracy; (b)
where our use of the data is unlawful but you do not
want us to erase it; (c) 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; or (d) you
have objected to our use of your data but we need to
verify whether we have overriding legitimate grounds to
use it.
- To request a copy of your personal data from us in a
commonly used and machine-readable format or that we
transmit your personal data to another data controller.
- Not to be subject to automated decision-making,
including profiling, which has legal or other
significant effects on you.
- To access information held about you. 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. Alternatively, we
may refuse to comply with your request in these
circumstances.
You can exercise any of the above rights at any time by
contacting us or by email to sales@lofyxsounds.com.
9. Links to and from our site
Our site may, from time to time, contain links to and from
the websites of our partners and affiliates. If you follow a
link to any of these websites, please note that these
websites have their own privacy policies and that we do not
accept any responsibility or liability for these policies.
Please check these policies before you submit any personal
data to these websites.
10. Changes to your personal data
It is important that the personal data we hold about you is
accurate and current. Please keep us informed if your
personal data changes during your relationship with us.
11. Changes to our privacy policy
Any changes we make to our privacy policy in the future will
be posted on this page. Please check back frequently to see
any updates or changes to our privacy policy.
12. Cookies
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. Our cookie policy is available at lofyxsounds.com/cookies.
13. Contact
Questions, comments and requests regarding this privacy
policy are welcomed and should be addressed to emailed to sales@lofyxsounds.com.
If you have any complaints relating to our privacy policy or
our use of your personal data, please contact us by email to sales@lofyxsounds.com.
You also have the right to make a complaint to your local
regulator in relation to data protection issues. In the UK,
the Information Commissioner’s Office (ICO) is the relevant
authority and further information can be found at
www.ico.org.uk.
