1.1 Information that relates directly to you (e.g. your name, email).
1.2 Information that does not directly identify you (e.g. how you might browse our website or use our Apps).
(1) Your IP address through the placement of cookies (see Sections 6 and 7 on cookies and their management, below);
(2) Location data, which might be gained through your IP address or GPS data (see Section 3 (4), below).
2.1 We might use your information to:
(1) Remember you when you visit our website and see how your journey through it by using cookies. We explain what cookies are in Section 6 and how you can manage them in Section 7, below;
(2) Remember you when you use an
App to analyse how you use it and to serve you with advertisements based on your interests. Section 3.1 (4) explains how we do this
(3) Serve you advertisements on selected, third-party websites that make their advertising space available to us. We call this “Audience Extension” and we do this by using retargeting cookies. We explain what cookies are in Section 6 and how you can manage them in Section 7, below;
(4) Identify your interests. We might then put your information in aggregated form into groupings (known as “segments”) by a particular audience, which means we can serve you advertisements and offers that will interest you within the websites and Apps, including by reference to data we receive from third parties. Please see Sections 6 and 7 for more information about cookies and how we serve you more targeted messaging;
(5) Make sure the products and services we provide to you are correctly administered;
(6) Contact you to let you know about any of our products, services or promotions (which may in some cases be provided by third parties), including by email, mail, telephone, or SMS text message. We may also send you App or Web notifications.
We will always act having regard to your preferences. Please see Section 4 to understand more about how you provide and can manage your preferences.
(7) We may also contact you directly via social media in relation to any competitions and/or prize draws you have entered.
(8) Make sure materials on the website or in Apps are presented in the most effective way for you and your computer or mobile device;
(9) Collect and log numeric internet addresses to improve the website and to monitor website usage;
(10) Assess and understand our readers’ feedback and identify usage hotspots;
2.2 If you have subscribed to any of our services, we will use the information you provide to keep you updated on those services unless you have told us otherwise.
3.1 Information is gathered in the following ways:
(1) indirectly (e.g. using website technology or technology when you use our Apps
on a mobile device); and
(2) directly (e.g. signing up for newsletter, download an App or you otherwise provide your information when you interact with us).
(3) through your device (e.g. mobile, PC or tablet) where you have enabled location services for the applicable App or browser. This may be used for location targeted services or advertising in accordance with your preferences, which may be adjusted either on your device or via server, App or website preferences.
(4) by applying an anonymous in-App identifier to your mobile device and using the services of Localytics and Adobe Analytics to gather the information.
(5) through location technology for mobile web created by Confetti. This is based on machine learning algorithms which analyze data from different connection types. These include fixed http and https connections, location consent requests on https sites and from mobiles Apps using a https connections. You can opt-out of this service by contacting us via email firstname.lastname@example.org .
(6) through social sign-on. We may offer a quick registration option using your existing social media accounts via an App or the website. When you use social sign-on, we will gather the information you have already used in the process of registering for that social media site (in accordance with your preferences provided to that site and/or to us at the point that you use our social sign-on) and your social media account will be linked to your CPP luxury account, including in our providing social media messaging to you (See Section 5.2, below on de-linking accounts);
(7) When you will subscribe to CPP luxury we may also use a card updater service to automatically update your credit or debit card. This service is facilitated by your credit or debit card issuer, whom you should contact for further information
(8) in the past we may have obtained certain additional details through a telephone number appending service where we have had contact details for you but did not have your phone number or needed to update your phone number. We will not use phone numbers that are gathered this way where those numbers are registered with the Telephone Preference Service. We no longer append data in this way.
(8) We may also overlay additional demographic and lifestyle data from CACI (www.caci.co.uk) to help us understand what else you might be interested in for direct marketing and insight purposes. These segmentations are built using a variety of sources, including publicly available data (such as the electoral register and the UK Census) or derived from surveys and questionnaires. You can opt out of having your personal information profiled in this way by contacting us via email email@example.com. See Section 5, below.
4.1 We always seek to explain why and how we might contact you at the point you give your information to us. We may contact you by email, phone, post and sms text. We may also contact you through App or Web notifications.
4.2 We also provide the means for you to grant or withhold your permission for us to contact you. We do this by using opt-in boxes or unsubscribe options. We use these to gain your permission to contact you about our wider range of goods and services (including those provided by our partners).
4.3 Sometimes, we need your information to be able to contact you to provide the service you wish to use. In those cases, by signing up to the service you give us permission to send you service communications and we will not offer you the chance to opt-out from receiving those messages.
4.4 We might also offer you the opportunity to hear from specific companies and organisations that we might work in association with. We will always name those companies and organisations and provide you with the opportunity to opt-out.
4.5 If there is no information about companies , it’s because we will not use your information for any other purpose than that for which you give it (see Section 3.2).
4.6 If you have signed up to receive marketing from us by text, to stop this, please contact us via email firstname.lastname@example.org.
4.7 You can manage your App preferences within you mobile device’s Settings.
5.1 You will be able update your details and marketing preferences by accessing your account pages on the website, by emailing email@example.com or by writing to us at Luxury Transumer LTD, International House, 24 Holborn Viaduct, London,EC1A2BN.
5.2 You will be able de-link your social media account from your CPP luxury account by emailing firstname.lastname@example.org. De-linking your account will not change your marketing preferences unless you specifically request it.
5.3 You have the right to access the personal information held about you. To obtain a copy of that personal information, please send an email to email@example.com. You will have to provide proof of identification.
6.2 We use the following types of cookie:
(1) Analytics cookies that anonymously remember your computer or mobile device when you visit our website. They keep track of browsing patterns and help us to build up a profile of how our readers use the website. We might use that information to serve advertisements that might be of particular interest to you on our and other websites (see Section 7.5).
(2) Service cookies that help us to make our website work as efficiently as possible; remember your registration and login details; remember your settings preferences; and meter the number of pages you view for the purpose of administering subscriptions to CPP Luxury.
(3) Third party advertising and analytics cookies, which are placed by or on behalf of independent advertisers who may advertise on our site. These cookies may be placed within the advertisement and elsewhere on our site. They are anonymous – they cannot identify individuals. They are used for statistical analysis by allowing the advertiser to count how many people have seen their advertisement or have seen it more than once. They might also allow the advertiser to tailor advertising to you when you visit other websites.
6.3 We have no access to third party cookies and third party organisations have no access to ours. The third party organisations that place cookies have their own strict privacy policies.
7.1 Most browsers allow you to turn off cookies. To do this look at the “help” menu on your browser. Switching off cookies may restrict your use of the website and/or delay or affect the way in which it operates.
7.2 We also use third party cookies. These are cookies that may be read by third parties (for example if you have used social sign-on and have the option to like or comment using your social media account). If you would prefer to just restrict third party cookies, here is cookie management tool we may use:
Alternatively, visit www.youronlinechoices.com or click on the AdChoices logo that you may see in the corner of advertisements that carry behavioural targeting cookies.
7.3 We use various third parties to provide us with information to help us learn about how users use our website. To find out more about how we use these third party services click on their names, below:
7.4 If you would like to disable “third party” cookies generated by advertisers or providers of targeted advertising services, you can turn them off by going to the third party’s website and getting them to generate a one-time “no thanks” cookie that will stop any further cookies being written to your device
7.5 We also use a data management platform. We use the data this platform records to better understand our users’ interests, so that we can provide better and relevant Advertiser services based on this information.
7.6 You can also visit the trade body representing these advertising companies for more information on how to opt out of these cookies: http://youronlinechoices.com/
8.2 By detecting ad blockers, we do not store any information on your device and we do not process any of your personal data.
8.3 We may display a message to advise you that we have detected that you are using and ad blocker
8.4 We reserve the right to restrict your access to some or all of our website while you have an ad blocker turned on.
9.1 The password you may provide when will be able registering with the website is encrypted to ensure protection against unauthorised access to your personal information.
9.2 We invest in high-quality security and do our utmost to protect user privacy. No data transmission over the Internet can be entirely secure, and therefore we cannot guarantee the security of your personal information and/or use of the website. Any information that you send is at your own risk and may be read by others. However once we have received your personal information we use strict procedures to protect the security of your personal information.
10.1 We may disclose your personal information to third parties and their advisers if we are approached by a potential buyer in connection with the potential sale of our business, or of any part of it. Should we proceed to sell or reconstitute any part of our business that holds your personal information, it will be necessary in some circumstances to share or transfer that information to the buyer or new entity: for example, so that they can continue to provide continuity of service to you. You will always be notified of such a change of control or ownership, and will be given the opportunity to object or opt out of any further communications from us or the buyer or new entity, except where such use of your personal information is necessary for a lawful purpose (such as a legal obligation or right, or where necessary to perform an existing contract with you)
10.2 We may disclose your personal information if we are required to do so by law, or if in good faith we believe such action is necessary to comply with the law a legal obligation.
10.3 We sometimes share your personal information with third parties who are our subcontractors or providers of various products and services on our behalf e.g. the providers of the services listed below.
10.5 Except as set out in Section 10.1 above, we never sell personal information, or pass it to third parties outside of the Luxury Transumer LTD for their own marketing purposes, without your permission.
11.1 The personal information that we collect from you may be sent and stored outside the European Economic Area (“EEA”) in order to carry out the activities listed in “Use of Your Information”.
12.1 If we change our Policy, we will post the changes on this page. Please check the website regularly for any changes to this Policy.
13.1 If you believe that we have not adhered to this Policy, please notify us by email at firstname.lastname@example.org and we will try to solve the problem promptly.
This Policy was last updated on 22th May, 2018.