Last updated on 22nd May 2018 to comply with the new Data Protection Regulations (EU regulation – GDPR) that are coming into force on May 25th 2018.
For the purpose of the Data Protection Act 1998 (the Act), the data controller is Luxenta Cleaning Limited, a company registered at Unit 4 A Ground floor, College Mews, St. Ann’s Hill, London, SW18 2SJ with Company N: 09603912. We are registered as a data controller with the ICO under reference number ZA373276.
1. IMPORTANT INFORMATION
Our website is not intended for children and we do not knowingly collect data relating to children.
Luxenta Cleaning Limited is the controller and responsible for your personal data (“Luxenta Clenaing”, “we”, “us” or “our”).
Glossary of terms:
Data Privacy Manager:
for the attention of: Galina Mihneva
by email to: email@example.com
by post to: the DPM, Luxenta Cleaning, 43 Heaton Road, CR4 2BW.
Your duty to inform us of changes:
It is important that the data we hold about you is accurate and current, therefore please keep us informed of any changes to your personal data.
2. THE DATA WE COLLECT ABOUT YOU
We may collect, use, store and transfer the types of personal data about you listed in Part 1 of Schedule 1
We also collect, use and share aggregated data. However, if we combine aggregated data with your personal data so that it can directly or indirectly identify you, we treat this as your personal data.
We do not collect any special categories of personal data or any information about criminal convictions and offences.
Failure to provide personal data:
If we are required by law, or under the terms of a contract we have with you, to collect your personal data and you fail to provide it, we may not be able to enter into performing the contract with you and, we may have to cancel a service. We will notify you of this at the relevant time.
|Contact data||billing address, home address, email address and telephone number|
|Financial data||bank account details|
|Identity data||first name, maiden name, last name|
|Property data||description of your household or business environment, details of any pets you may have and any information about you or your property revealed in photographs of your property which you provide to us (or which you permit us to take), feedback responses.|
|Technical data||internet protocol (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.|
|Transaction data||details about payments to and from you and other details of cleaning services you have booked with us|
3. HOW PERSONAL DATA IS COLLECTED
Personal data shall be processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’).
Luxenta Cleaning may collect and process information, which you choose to provide voluntarily and with your consent, when you:
submit a booking enquiry through our website and/or social media apps;
make a booking/order through our website and/or social media apps;
complete contact or enquiry forms on, or otherwise provide information via, our websites and/or social media;
complete any voluntary surveys we may ask you to participate in from time to time;
send feedback to us via our website and/or social media;
respond to our marketing communications;
correspond with us by telephone, post or email;
4. COOKIES AND COOKIES POLICY
We automatically collect personal data (technical and usage) when you browse or interact with our website, by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites which use our cookies.
For detailed information on the cookies we use please browse our Cookies Policy.
5. HOW WE MAY USE YOUR PERSONAL DATA –
UNSUBSCRIBE FROM OUR MAILING LIST
Luxenta Cleaning use the information you share with us as follows:
to manage your booking or respond to booking enquiry and to arrange the cleaning services;
to provide you with the information, products and services that you request from us;
to communicate with you about any comments, complaints, queries or feedback you might have about us or the Services;
to notify you about any changes to our Terms and Conditions, to communicate any information about your booking with you;
to provide you with information about services we offer that we feel may interest you by post, telephone or email.
to ensure that content on our website and our social media is presented in the most effective manner for you and your computer and/or device;
to provide you with information about services we offer that we feel may interest you by post, telephone, SMS or email. We will send that information by SMS or email only if:
(i) you have consented to this; or (ii) the information is about products and services similar to those which were the subject of a previous sale or negotiation of a sale to you (and you have not opted out of receiving such marketing messages);
Specifically, we will provide your data to the cleaner who is assigned to you, for the purpose of providing the cleaning services. This information may include (i) your name, address and contact details; (ii) the details about your property and the services you require, together with any relevant photographs you may have provided; (iii) the non-binding quote we have provided to you.
If you do not want us to use the information and to send you any newsletters or promotions and surveys, please unsubscribe following the link below. You can also withdraw your consent to marketing at any time by contacting our DPM. Even if you opt out of receiving marketing, we may still use your personal data for other purposes provided we have a lawful basis to do so.
Part 2 of Schedule 1 sets out the lawful basis we will rely on to process your personal data.
|Consent||you have given your express consent for us to process your personal data for a specific purpose/ cleaning service.|
|Contract||the processing is necessary for us to perform our contractual obligations with you under our T&C, or because you have asked us to take specific steps before setting up a cleaning service for you.|
|Legal obligation||the processing is necessary for us to comply with legal or regulatory obligation.|
|Legitimate interests||the processing is necessary for our or a third party’s legitimate interest e.g. in order for us to provide the best service to you via our website. Before we process your personal data on this basis we make sure we consider and balance any potential impact on you, and we will not use your personal data on this basis where such impact outweighs our interest.|
Set out below are specific details of the processing activities we undertake with your personal data and the lawful basis for doing this.
|Purpose/Activity||Type of data||Lawful basis for processing|
|to register you as a new customer||identity & contact||to perform our service set in T&C.|
|to process and complete your booking, manage payments, fees and charges and debt recovery||identity, contact, financial, transaction and marketing & communications||(i) to perform our contract with you;|
(ii) as necessary for our legitimate interest in recovering debts due to us.
(ii) as necessary to comply with a legal obligation
(iii) as necessary for our legitimate interests in keeping our records updated and analysing how customers use our products/services.
|to enable you to partake in promotional offers (including free products and services), prize draws, competitions or complete surveys||identity, contact, profile, usage & marketing & communications||(i) perform our contract with you|
(ii) as necessary for our legitimate interests in analysing how customers use our 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)||identity, contact & technical||(i) as necessary for our legitimate interests in 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|
(ii) as necessary to comply with any legal obligations
|to deliver relevant website content/advertising to you and measure or understand the effectiveness of our advertising||identity, contact, profile, usage, marketing & communications & technical||as necessary for our legitimate interests in studying how customers use our services, to develop them, to grow our business and to inform our marketing strategy|
|to use data analytics to improve our website, services, marketing, customer relationships and experiences||technical & usage||as necessary for our legitimate interests to define types of customers for 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 services that may be of interest to you, including promotional offers||identity, contact, technical, usage & profile||as necessary for our legitimate interests to develop our products/services and grow our business|
6. DISCLOSURE OF YOUR INFORMATION
We may disclose your personal information to any member of our group of companies, which means the company registered in England and Wales: Luxenta Cleaning Ltd and Lux D&G Ltd; and our partners, service providers, licensors, licensees or any other third parties related to us.
Luxenta Cleaning may disclose your personal information to third parties:
If you do not make payments that you owe in relation to any services provided to you, in which case we may disclose your personal data to credit reference agencies and to fraud prevention agencies for the purposes of fraud prevention. We may also disclose your personal data to debt collection agencies which may use your information to trace your whereabouts and recover the debts. The information which we provide to such agencies may in turn be provided by those agencies to other organisations which may use your personal data to perform similar checks. Information recorded by fraud prevention agencies may be accessed by organisations in other jurisdictions; If we are forced to protect our own rights, property and operations (enforcing contract performance or pursuing remedies or limiting damages we may sustain).
7. DATA SECURITY
We are committed to securing personal information and any data we collect from you. 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. We also limit access to your personal data to those employees, contractors and other third parties who have a business need to know and they can only process your personal data on our instructions and will be subject to a duty of confidentiality.
We have procedures in place 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.
However, please note that no server, network or data transmission over the Internet is 100% secure and we cannot guarantee the security of any information transmitted through our website and make no assurance about our ability to prevent any such loss or misuse. By choosing to share any information with us, you are accepting this risk.
8. THIRD-PARTY LINKS
Our website may, from time to time, contain links to and from third-party websites, plug-ins and applications. If you follow a link to any of these websites, plug-ins and applications, please note that they 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, plug-ins and applications. We welcome any feedback about third-party websites linked to/ from our websites.
9. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us. However, we are legally required 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.
10. YOUR LEGAL RIGHTS
You have certain rights in certain circumstances under data protection law. These are set out in full in Part 3 of Schedule 1. If you wish to exercise any of your rights, please contact our DPM.
You will not have to pay a fee to exercise any of your rights. However, if your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee for this information or refuse to comply with your request.
We may request specific information from you to help us confirm your identity when you contact us and ensure. This is a security measure to ensure that personal data is not disclosed to any person who does not have the right to receive it.
We try to respond to all legitimate requests within one month. Occasionally it may 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.
|Access your Data||you can ask for access to and a copy of your personal data and can check we are lawfully processing it|
|Correction||you can ask us to correct any incomplete or inaccurate personal data we hold about you|
|Erasure||you can ask us to delete or remove your personal data where:|
(a) there is no good reason for us continuing to process it;
(b) you have successfully exercised your right to object (see below);
(c) we may have processed your information unlawfully; or
(d) we are required to erase your personal data to comply with local law.
We may not always be able to comply with your request for specific legal reasons, which will be notified to you at the time of your request.
|Object||you can object to the processing of your personal data where:|
(a) where we are relying on our legitimate interest (or those of a third party) as the basis for processing your personal data, if you feel it impacts on your fundamental rights and freedoms;
(b) 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 and in such circumstances, we can continue to process your persona data for such purposes.
|Restrict Processing||you can ask us to us to suspend or restrict the processing of your personal data, if:|
(a) you want us to establish the accuracy of your personal data;
(b) our use of your personal data is unlawful, but you do not want us to erase it;
(c) you need us to hold your personal data (where 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 personal data, but we need to verify whether we have overriding legitimate grounds to use it.
|Request a Transfer||you can request a transfer of your personal data which is held in an automated manner and which you provided your consent for us to process such personal data or which we need to process to perform our contact with you, to you or a third party. We will provide your personal data in a structured, commonly used, machine-readable format.|
|Withdraw Your Consent||you can withdraw your consent at any time (where we are relying on consent to process your personal data). This does not affect the lawfulness of any processing carried out before you withdraw your consent.|
|Service Providers||acting as cleaning company based in the United Kingdom who provide cleaning services: Domestic cleaning, Carpet cleaning, One off cleanings, End of tenancy cleaning, After builders Cleaning, ironing services.|
|Professional Advisors||acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.|
|HM Revenue & Customs, Regulators and other Authorities||acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.|
|Third Parties||third parties 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 Notice|
|Aggregated Data||information such as statistical or demographic data which may be derived from personal data but which cannot by itself identify a data subject|
|Controller||a body that determines the purposes and means of processing personal data|
|Data Subject||an individual living person identified by personal data (which will generally be you)|
|Personal Data||information identifying a data subject from that data alone or with other data we may hold but it does not include anonymised or aggregated data|
|Processor||a body that is responsible for processing personal data on behalf of a controller.|
|Special Categories of Personal Data||information about race, ethnicity political opinions, religious or philosophical beliefs, trade union membership, health, genetic, biometric data, sex life, sexual orientation.|
|ICO||Information Commissioner’s Office, the UK supervisory authority for data protection issues.|