Privacy Policy

1.       Introduction

1.1    Lux Vortex is committed to safeguarding the privacy of our website visitors and service users.

1.2    This policy applies where we are acting as a data controller with respect to the personal data of [our website visitors and service users]; in other words, where we determine the purposes and means of the processing of that personal data.

1.3    In this policy, "we", "us" and "our" refer to [lux vortex].[ For more information about us, see Section 5].

2.       Credit

2.1    This document was created using a template from SEQ Legal (https://seqlegal.com/free-legal-documents/privacy-policy).

3.       How we use your personal data

3.1    In this Section 3 we have set out:

(a)    the general categories of personal data that we may process;

(b)    [in the case of personal data that we did not obtain directly from you, the source and specific categories of that data];

(c)    the purposes for which we may process personal data; and

(d)    the legal bases of the processing.

3.2    We may process [data about your use of our website and services] ("usage data"). The usage data may include [your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use]. The source of the usage data is [our analytics tracking system]. This usage data may be processed [for the purposes of analysing the use of the website and services]. The legal basis for this processing is [consent] OR [our legitimate interests, namely [monitoring and improving our website and services]].

3.3    We may process [your website user account data] ("account data").[ The account data may [include your name and email address].][ The source of the account data is [you or your employer].] The account data may be processed [for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.] The legal basis for this processing is [consent] OR [our legitimate interests, namely [the proper administration of our website and business]] OR [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract].

3.4    We may process [information that you post for publication on our website or through our services] ("publication data"). The publication data may be processed [for the purposes of enabling such publication and administering our website and services]. The legal basis for this processing is [consent] OR [our legitimate interests, namely [the proper administration of our website and business]] OR [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract].

3.5    We may process [information contained in any enquiry you submit to us regarding goods and/or services] ("enquiry data"). The enquiry data may be processed [for the purposes of offering, marketing and selling relevant goods and/or services to you]. The legal basis for this processing is [consent] OR [our legitimate interests, namely [the proper administration of our website and business]] OR [the performance of a contract between you and us and/or the taking steps, at your request, to enter into such a contract].

3.6    We may process [information relating to transactions, including purchases of goods and/or services, that you enter into with us and/or through our website] ("transaction data").[ The transaction data may include [your contact details, your card details and the transaction details].][ The source of the transaction data is [you and/or our payment services provider].] The transaction data may be processed [for the purpose of supplying the purchased goods and/or services and keeping proper records of those transactions]. The legal basis for this processing is [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract; providing that, if you are not the person contracting with us, the legal basis for this processing is our legitimate interests, namely [the proper administration of our website and business].

3.7    We may process [information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters] ("notification data"). The notification data may be processed [for the purposes of sending you the relevant notifications and/or newsletters]. The legal basis for this processing is [consent] OR [our legitimate interests, namely [communications with our website visitors and service users]] OR [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract].

3.8    We may process [identify general category of data].[ This data may include [list specific items of data].][ The source of this data is [identify source].] This data may be processed for [specify purposes]. The legal basis for this processing is [consent] OR [our legitimate interests, namely [specify legitimate interests]] OR [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract].

3.9    We may process [any of your personal data identified in this policy] where necessary for [the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure]. The legal basis for this processing is our legitimate interests, namely [the protection and assertion of our legal rights, your legal rights and the legal rights of others].

3.10  We may process [any of your personal data identified in this policy] where necessary for [the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice]. The legal basis for this processing is our legitimate interests, namely [the proper protection of our business against risks].

3.11  In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process [any of your personal data] where such processing is necessary[ for compliance with a legal obligation to which we are subject, or] in order to protect your vital interests or the vital interests of another natural person.

3.12  Please do not supply any other person's personal data to us, unless we prompt you to do so.

4.       Providing your personal data to others

4.1    We may disclose [your personal data] to [our insurers and/or professional advisers] insofar as reasonably necessary for the purposes of [obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure].

4.2   In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.[ We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.]

5.       Your rights

5.1    In this Section 5, we have listed the rights that you have under data protection law.

5.2    Your principal rights under data protection law are:

(a)    the right to access - you can ask for copies of your personal data;

(b)    the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;

(c)    the right to erasure - you can ask us to erase your personal data;

(d)    the right to restrict processing - you can ask use to restrict the processing of your personal data;

(e)    the right to object to processing - you can object to the processing of your personal data;

(f)    the right to data portability - you can ask that we transfer your personal data to another organisation or to you;

(g)    the right to complain to a supervisory authority - you can complain about our processing of your personal data; and

(h)    the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

5.3    These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.

5.4    You may exercise any of your rights in relation to your personal data [by written notice to us, using the contact details set out below].

Contact Info

Javastraat 20-1

1094 HH Amsterdam

info@luxvortex.com

+31 6 510 535 60