This Privacy and Cookies Policy (the "Policy") applies to the website https://raffolux.com (the “Website”) and the Raffolux App (the "App"), both of which are run by Raffolux Ltd ("Raffolux"), whose registered office address is, Raffolux Ltd, Unit 5, 10 Beechen Grove, Watford, Hertfordshire, WD17 2AD (company number 10962686). All references in this Policy to "we", "us", and "our" are to Raffolux.
Raffolux recognises the importance of honest and responsible use of your personal information, and we are committed to protecting and respecting your privacy. This Policy explains how Raffolux collects, uses and discloses personal information about you when you visit the Website or the App, and when you contact Raffolux, whether by e-mail, post, fax or telephone using the contact options on the Website and App. The information you provide to us through the Website and the App will initially be collected by Raffolux, but may then be shared with other companies to the extent that it is necessary to do so for Raffolux to operate effectively.
It is important to Raffolux that you feel completely comfortable in visiting and using the Website and the App.
For the purposes of the Data Protection Act 2018 (the "Act") and the General Data Protection Regulation 2016/679 (the "GDPR"), the data controller is Raffolux.
The legal basis on which Raffolux relies to process your personal information includes:
In most cases, the information that Raffolux processes about you is required to deal with your request or registration, or is required by law, or is necessary for the exercise of Raffolux’s legitimate business interests and needs, in which case special care is taken to safeguard your rights and to ensure any such use is proportionate.
Raffolux may also convert personal information into anonymous data and use it (normally on an aggregated statistical basis) for research and analysis to improve Raffolux’s performance.
If you want to contact Raffolux or to use certain facilities we provide on the Website, you will need to provide us with some additional personal information so that we can liaise with you and deal with your request, query or application. If you do choose to provide Raffolux with your personal information, Raffolux will collect that information for our own use and for the purposes described in this Policy.
Where you choose to provide personal details to Raffolux, we may collect, store and process the following personal information from you:
This information will be collected primarily from you as information voluntarily provided to us, but we may also collect it where lawful to do so from (and combine it with information from) public sources, third party service providers, individuals whom you have indicated have agreed for you to provide their personal information, government, tax or law enforcement agencies, and other third parties. We may also collect personal information about you from your use of other company services.
Raffolux may use information about you for purposes described in this Policy or disclosed to you on our Website and App or with our services. For example, we may use information about you for the following purposes, all of which we believe to be in our legitimate business interests:
Your personal information will be made available for the purposes mentioned above (or as otherwise notified to you from time to time), on a 'need-to-know' basis and only to responsible management, human resources, accounting, legal, audit, compliance, information technology and other Raffolux staff who properly need to know these details for their functions within Raffolux. Please note that certain individuals who will see your personal information may not be based at Raffolux or in your country of residence (please see below).
We may share personal information within Raffolux as needed for reasonable management, analysis, planning and decision making, including in relation to taking decisions regarding the expansion and promotion of our service offering and for use by Raffolux for the other purposes described in this Policy.
Your personal information may also be made available to third parties (within or outside Raffolux) providing relevant services under contract to Raffolux (see below for further details), such as credit and debit card processors, auditors and compliance managers, provider or call centres and IT hosting and IT maintenance providers. These companies may use information about you to perform their functions on our behalf. Subject to your consent when entering a charity prize draw or raffle, Raffolux may also share your personal data via secure transfer to any specified third party organisations. Those organisations will process that data for their own respective purposes, and will become the controller of that personal data. Raffolux has put in place various security and data privacy measures, inclusive in scope of such third parties, in order to protect personal information and shall seek to comply with applicable legal requirements.
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA that work for us or for one of our providers. This may include staff engaged in, among other things, the fulfilment of any contract with you, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.
We will not sell your personal information to any third party other than as part of any restructuring of Raffolux or sale of the business.
Raffolux may wish to provide you with information about new products, services, promotions and offers which may be of interest to you, and may invite you to take part in market research or request feedback on our products and services. This communication may occur by e-mail, telephone, post, social media or SMS. We will obtain your consent and advise you of how to opt-out of receiving such communications where we are required to do so in accordance with applicable law.
Raffolux takes reasonable steps to maintain appropriate physical, technical and administrative security to help prevent loss, misuse, unauthorised access, disclosure or modification of personal information. While we take these reasonable efforts to safeguard your personal information, we cannot guarantee the security of any personal information you disclose online. You accept the inherent security implications of dealing online and will not hold us responsible for any breach of security unless such breach has been caused by the specific negligence of Raffolux, or our agents.
You have the right to review and access your personal information held by Raffolux.
You also have the right to ask us to rectify, block, complete and delete your personal information, to restrict its use, and to 'port' your personal information (that is, to ask us to provide it to you in a structured, commonly used and machine readable format and to transmit it directly to another organisation).
In addition, you have the right to request further information about the handling of your personal information.
If you wish to do so, or to notify Raffolux of a change in your details, please contact firstname.lastname@example.org and/or post to Raffolux Ltd, Unit 5, 10 Beechen Grove, Watford, Hertfordshire, WD17 2AD.
There are exceptions to these rights, however. For example, access to personal information may be denied in some circumstances if making the information available would reveal personal information about another person, or if we are legally prevented from disclosing such information. In addition, we may be able to retain data even if you withdraw your consent, where we can demonstrate that we have a legal requirement to process and store your data.
If you have a question about the use of your personal information, or wish to file a complaint about it, please contact us using the contact details set out above.
Finally, if you have unresolved concerns, you also have the right to complain to the data protection authorities.
When we store your information, we do so for as long as necessary to (i) fulfil the specific purposes set out in this notice for which your personal information was collected and (ii) to comply with our legal obligations or enforce our legal rights.
We also use Google Analytics on the Website and App to collect information about your online activity on the Site, such as the Web pages you visit and the links you click on the Website and App. We use the information to compile reports and to help us improve the Website and App. The cookies collect information in an anonymous form, including the number of visitors to the Website and App, where visitors have come to the Website and App from and the pages they visited.
For more information about the information gathered using Google Analytics please visit http://www.google.com/intl/en/analytics/privacyoverview.html. You can prevent these cookies by selecting the appropriate settings on your browser. If you do this you may not be able to use the full functionality of this Site. You may download and install the Google Analytics Opt-out Browser Add-on available here: http://tools.google.com/dlpage/gaoptout.
We only use category D cookies as defined in the international chamber of Commerce United Kingdom Cookie Guide:
|Cookie name/Type||Expiration Period||Purpose||Category of Cookie as defined in the ICC Cookie Guide|
|Google Analytics utma||2 years from set/update||Provides a unique ID for each Web browser that visits the Website or App.||D. Targeting/Advertising|
|Google Analytics utmb||Session 30 minutes from set/update||Used to establish and continue a user session with the Website or App.||D. Targeting/Advertising|
|Google Analytics utmc||Session (these cookies typically expire at the end of your session, i.e. when you close your browser)||Used to establish and continue a user session with this website.||D. Targeting/Advertising|
|Lucky Orange||Session (these cookies typically expire at the end of your session, i.e. when you close your browser)||Used to analyse how users interat with this website||D. Targeting/Advertising|
You can usually choose to set your browser to warn you when a cookie is being sent or to remove or reject cookies. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookie settings. If you choose to remove or reject cookies, it will affect many features or services on our Website and App.
If you agree to cookies from our Website or App by clicking on the "I agree" button, we will set cookies from category D on your device. If you wish to delete the cookies we have set on your device, please refer to your browser Help menu.
If you do nothing to indicate your cookie preference for our Website or App (i.e. if you do not click on "I agree"), category D cookies will not be set on your device. To modify your cookie settings, please refer to the Help menu of your browser.
If you say no to cookies on our Website or App, we will not set category D cookies on your device. Please note that if you do this you may not be able to use the full functionality of our Site.
We keep this Policy under regular review. We may change this Policy from time to time by updating this page in order to reflect changes in the law and/or our privacy practices. The date at the top of this Policy will be updated accordingly.
We encourage you to check the date of this Policy when you visit the Website or App for any updates or changes. We will notify you of any modified versions of this Policy that might materially affect the way we use or disclose your personal information.
If you have any questions about this Policy, please contact us by e-mail at email@example.com, or by mail at:
Raffolux Ltd, Unit 5, 10 Beechen Grove, Watford, Hertfordshire, WD17 2AD.