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, The Maylands Building, Hemel Hempstead, Hertfordshire, England, HP2 7TG (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.

It is important to Raffolux that you feel completely comfortable in visiting and using the Website and the App.

Our collection of website use information may involve the use of cookies and Web beacons. Please see the "Cookies" section below for more information.

DATA PROTECTION

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.

LEGAL BASIS FOR THE USE OF PERSONAL DATA

The legal basis on which Raffolux relies to process your personal information includes:

• On some occasions, Raffolux processes your data with your consent (for example, when you agree that Raffolux may place cookies on your device or process information that you input into our website).
• On other occasions, Raffolux processes your data when we need to do this to fulfil a contract with you (for example, if you win a prize in a competition that Raffolux promoted or where we are required to do this by law, e.g. to comply with record keeping obligations).
• Raffolux also processes your data when it is in Raffolux’s legitimate interests to do this, and when these interests are not overridden by your data protection rights (including, for example, when Raffolux shares data with our affiliates).

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.

PERSONAL INFORMATION RAFFOLUX COLLECTS FROM YOU

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:

• if you create an account – your password, e-mail address and your full name (telephone is optional);
• the reason for your contact, which may be an enquiry, a request or enquiry on behalf of someone else, providing a comment, or details in relation to a possible or existing competition;
• your contact and marketing preferences;
• if you take a survey or interact with us in various other ways – demographics information and information about subjects that may interest you;
• standard internet and website log information and details of patterns about how visitors behave on our Website and App. The information we may collect includes information about your Internet service provider, your operating system, browser type, domain name, the Internet Protocol (IP) address of your computer (or other electronic Internet-enabled device), your access times, the website that referred you to us, the Web pages you request and the date and time of those requests;
• where you “like” us or make posts on our pages on social networking websites.
  

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.

USES MADE OF YOUR PERSONAL INFORMATION

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:

• to operate competitions promoted on the Website and App;
• to respond to and/or deal with any request or enquiry you may raise;
• to improve our products and services and to ensure that content on the Website and App is presented in the most effective manner for you and for your device;
• to administer the Website and App;
• for internal record keeping;
• to contact you (directly, either by Raffolux or through a relevant partner or agent) by e-mail or phone for the above reasons;
• subject to your consent where required under applicable laws, to carry out direct marketing and/or e-mail marketing that you have requested;
• to perform any contract Raffolux has with you; and
• for compliance with legal, regulatory and other good governance obligations.

DISCLOSURE OF YOUR PERSONAL INFORMATION

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. 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 may disclose specific information upon lawful request by government authorities, law enforcement and regulatory authorities where required or permitted by law and for tax or other purposes. Personal information may also be released to external parties in response to legal process, and when required to comply with laws, or to enforce our agreements, corporate policies, and terms of use, or to protect the rights, property or safety of Raffolux, our employees, agents, customers, and others, as well as to parties to whom you authorise Raffolux to release your personal information.

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.

WHAT CHOICES DOES RAFFOLUX OFFER YOU WITH REGARD TO DIRECT MARKETING?

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.

WHAT SAFEGUARDS ARE IN PLACE TO PROTECT YOUR PERSONAL INFORMATION?

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.

WHAT RIGHTS DO YOU HAVE TO REVIEW AND AMEND YOUR PERSONAL INFORMATION?

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 support@raffolux.com and/or post to Raffolux Ltd, The Maylands Building, Hemel Hempstead, Hertfordshire, HP2 7TG.

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.

KEEPING YOU INFORMED

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.

INFORMATION ABOUT OUR USE OF COOKIES

We use cookies for certain areas of the Website and App. Cookies are small data files stored on your hard drive by a website. Cookies help us improve the Website and App, and your experience of them. We use cookies to see which areas and features are popular and to count visits to our websites, to recognise you as a returning visitor and to tailor your experience of the Website and/or App according to your preferences. Overall, cookies help us provide you with a better Website and App, by enabling us to monitor which pages you find useful and which you do not. We may also use cookies for targeting and/or advertising purposes. We may use Web beacons on our Website and App, or in our e-mails. Web beacons are electronic images that may be used to deliver cookies, count visits, understand usage of group websites and to tell if an e-mail has been opened and acted upon. Further details about cookie purposes and types are below. To delete or block cookies through your browser settings at any time, and for more general information about cookies including the difference between session and persistent cookies, visit www.allaboutcookies.org.

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:

1. "Targeting or advertising" cookies used to deliver adverts relevant to an identified machine or other device (not a named or otherwise identifiable person) which are tailored to interests associated with the website activity tied to that machine or device. For example, if a cookie on a third party website recognises that a particular product was purchased from a particular device, that cookie may “talk to” marketing cookies on the Website or App to ensure advertisements about similar products displayed on the Website or App are accessed from that device. These cookies are also used to limit the number of times a user sees an advertisement, as well as to help them measure the effectiveness of an advertising campaign. They may also remember that the Website or App has been visited from a device and share that information with marketing organisations. The marketing cookies on the Website and App are operated by third parties with our permission. Marketing cookies are used to monitor from which advertising source a user was directed towards the Website/App, so that we know whether it is worth us investing in that particular advertising source.