SUMMARY

If you are a customer of Luella Grey, we use your personal data to fulfil your orders with us, operate your online account, send marketing to you (where you have consented to that) and gain an understanding of your interest in our products so we can provide you with a more tailored service. To do this, we gather information and insights about your interactions with us over all our channels, your age, purchase history, website usage and other information to build a profile of you so we can provide personalised service such as information about products which we think will be of more interest to you given what we know about you.

If you are a visitor to our website, social media or contact us through these channels or by phone or letter, we will use your personal data to respond to your enquiry, query or complaint.

In this Privacy Notice, "we" or "us" refers to Enem Enterprises, the franchisee for Luella Grey London in Pakistan this Privacy Notice will apply to our website which refers to www.luellagrey.pk.

OVERVIEW

We take your privacy very seriously.  Please read this Privacy Notice carefully as it sets out important information about our processing and your rights:

• when you interact with us on our website, over the phone, by letter or on social media (as a customer or a visitor),
• as a customer
• as one of our wholesalers.

This notice explains what data we process, why, how it is legal and your rights. It applies to both retail and wholesale customers, and all interactions you have with us whether you use our website or social media, telephone us, write to us or speak to us at a trade show or in in-storeOW TO CONTACT US

If you have any questions about this Privacy Notice please contact us at info@luellagrey.pk or through the ‘Contact Us’ page on our website.

CHANGES TO THIS PRIVACY NOTICE

We may change this Privacy Notice from time to time by updating this page.  We will notify you of any significant changes by way of a banner on our Website. Changes will become effective from the next time that you interact with us or use your account.

WHAT PERSONAL DATA DO WE COLLECT?

This section sets out the categories of personal data we may hold about the different groups of people we interact with.

GENERAL CONTACTS THROUGH WEBSITE, OVER THE PHONE, BY LETTER, EMAIL OR ON SOCIAL MEDIA

• Your title and name
• Your contact details (including email address and mobile number)
• Other information that you provide in any correspondence or communication with us including feedback, suggestions and complaints

Cookies on our Website collect anonymous information about your browsing or shopping activity, website use, information about your computer, such as which browser you are using, your network location, the type of connection you are using (e.g. broadband, etc) but this information is anonymous and we cannot tell who you are.

CUSTOMERS

• Your title and name
• Your contact details (including email address and mobile number) and your password for your account on the Website
• Your postal address (including both your billing and delivery address)
• Age/date of birth (although this is optional)
• Purchases and orders made by you
• Your “wish list”
• Your alerts
• your payment card details
• Your online browsing activities on our Website when you are logged in to your account
• Your communication and marketing preferences

 

WHY DO WE PROCESS YOUR PERSONAL DATA?

• We use your personal data for the following reasons and we are allowed to do so on certain legal bases (please see section “How is processing your data lawful” for further details):

 

Type of data	Why we process your personal data	Legal basis for processing customer data
General contacts through website, over the phone, by letter or on social media
Your name, title, contact details, other information you provide in relation to your enquiry, query or complaint	To respond to and deal with your enquiry, query or complaint	Legitimate interests
Customers and Wholesalers
Your name, title, contact details, and password	To supply you with our products when you purchase them   To respond to your enquiries, queries, or complaints To operate your online account	Contract     Legitimate interests
Age and/or date of birth	To send you relevant promotion communications based on your demographic (this is an optional field, you do not have to provide this information)	Legitimate interests
Purchases and orders made by you and your online browsing activities	For market research purposes to better understand our customers’ behaviour, activities, preferences and needs and to improve and develop our existing products and services.	Legitimate interests
Your alerts	To send you communications letting you know the product is back in stock	Legitimate interests
Your payment card details	To take payment and fulfil your order, including doing anti-fraud checks	Contract and legal obligation
Your communication and marketing preferences	To send you relevant promotion communications	Consent
Profiling of our customers, in the aggregate and individually	We use the following tools to gather information about customers and potential customers: Google Analytics, Google Ad words, pixel placement technologies and cookies.  We will analyse the data gathered from these tools together with (i) data collected directly from you particularly your age and location, (ii) your browsing and purchasing activity through all our channels and (iii) your responses to marketing communications to develop profiles of our overall customer base, and of you individually.  The results of this analysis will allow us to tailor our contact with you so that we can provide you with a service that is most relevant to you including sending you information about products and offers that are best suited to you.	Legitimate interests

 

HOW IS PROCESSING YOUR PERSONAL DATA LAWFUL?

WE ARE ALLOWED TO PROCESS YOUR PERSONAL DATA ON THE FOLLOWING LEGAL BASES: 

• Legitimate interests

We are permitted to process your data if it is based on our ‘legitimate interests’ i.e. we have good, sensible, practical reasons for processing your data which is in the interests of Luella Grey. To do so, we have considered the impact on your interests and rights, and have placed appropriate safeguards to ensure that the intrusion on your privacy is reduced as much as possible. The section above explains the personal data processed on this basis and provides a description of our specific ‘legitimate interests’.   You can object to processing on the grounds of legitimate interests. See the section headed “Your Rights” to find out how.

• Contract

It is necessary for our performance of the contract you have agreed to enter with us (such as for the sale of our goods).  If you do not provide your personal data to us, we will not be able to carry out our obligations under the terms of your contract.

 

• Consent

Sometimes we want to use your personal data in a way that is entirely optional for you. On these occasions, we will ask for your consent to use your information for that purpose. You can withdraw your consent at any time. Currently, we only rely on consent as a legal basis for processing to send direct marketing to you.

WHO WILL HAVE ACCESS TO YOUR PERSONAL DATA?

We share your personal data with organisations acting as our processors for the website who will only have access to your personal data to provide a particular service to ensure the website operations and functionalities are properly delivered in the form of better UI/UX and order processing.

HOW WE KEEP YOUR PERSONAL DATA SECURE

We are committed to ensuring that your information is secure.

In order to prevent unauthorized access or disclosure we have put in place appropriate technical and organisational measures to safeguard, protect and secure your personal data against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access and any other unlawful forms of processing.  We aim to ensure that the level of security and the measures adopted to protect your personal data are appropriate for the risks presented by the nature and use of your personal data.

 WE FOLLOW RECOGNISED INDUSTRY PRACTICES FOR PROTECTING OUR IT ENVIRONMENT AND PHYSICAL FACILITIES.

If at any point you suspect or become aware of a security incident (i.e. your password is stolen or you receive suspicious communication from someone holding themselves out to be from Luella Grey or representing Luella Grey), please forward the communication to us or report the incident by email or in writing to the contact details at the top of this Privacy Notice as soon as possible.

When will we delete your data?

We will keep personal data for the following periods:

Category of Data	Retention Period
All data related to customer transactions	Six (6) years from the date of each transaction for data related to a particular transaction
Email address for marketing purposes	Until you withdraw your consent
Cookies information	Twenty four (24) months

 

We will not retain your data for longer than necessary for the purposes set out in this Privacy Notice.

YOUR RIGHTS: 

YOU HAVE THE FOLLOWING RIGHTS UNDER THE DATA PROTECTION LAWS:

• the right to object to processing of your personal data
• the right of access to personal data relating to you (known as data subject access request)
• the right to correct any mistakes in your information
• the right to restrict processing of your personal data
• the right to have your personal data ported to another controller
• the right to withdraw your consent (including to receiving marketing)
• the right to erasure

 

These rights are explained in more detail below. If you want to exercise any of your rights, please contact us (please see “How to contact us”).

We will respond to any rights that you exercise within a month of receiving your request, unless the request is particularly complex, in which case we will respond within three months.

You may object to us processing your personal data where we rely on a legitimate interest as our legal grounds for processing. 

If you object to us processing your personal data we must demonstrate compelling grounds for continuing to do so. We believe we have demonstrated compelling grounds in the section headed “How is processing your personal data lawful”.

RIGHT TO ACCESS PERSONAL DATA RELATING TO YOU

You may ask to see what personal data we hold about you and be provided with:

• a copy of the personal data
• details of the purpose for which the personal data is being or is to be processed
• details of the recipients or classes of recipients to whom the personal data is or may be disclosed, including if they are overseas and what protections are used for those overseas transfers
• the period for which the personal data is held (or the criteria we use to determine how long it is held)
• any information available about the source of that data
• whether we carry out an automated decision-making, or profiling, and where we do information about the logic involved and the envisaged outcome or consequences of that decision or profiling.

 

To help us find the information easily, please provide us as much information as possible about the type of information you would like to see.

RIGHT TO CORRECT ANY MISTAKES IN YOUR INFORMATION

You can require us to correct any mistakes in your information which we hold. If you would like to do this, please let us know what information is incorrect and what it should be replaced with.

RIGHT TO RESTRICT PROCESSING OF PERSONAL DATA

You may request that we stop processing your personal data temporarily if:

• you do not think that your data is accurate. We will start processing again once we have checked whether or not it is accurate
• the processing is unlawful but you do not want us to erase your data
• we no longer need the personal data for our processing, but you need the data to establish, exercise or defend legal claims
• you have objected to processing because you believe that your interests should override our legitimate interests

 

RIGHT TO DATA PORTABILITY

You may ask for an electronic copy of your personal data which we hold electronically and which we process when we have entered into a contract with you. You can also ask us to provide this directly to another party.

RIGHT TO WITHDRAW CONSENT

You may withdraw any consent that you have given us to process your personal data at any time. This means that we will not be able to carry out any processing which required use of that personal data. If you want us to stop sending marketing, this may take a few days to implement in our systems.

RIGHT TO ERASURE

You can ask us to erase your personal data where:

• you do not believe that we need your data in order to process it for the purposes set out in this Privacy Notice
• if you had given us consent to process your data, you withdraw that consent and we cannot otherwise legally process your data
• you object to our processing and we do not have any legitimate interests that mean we can continue to process your data
• your data has been processed unlawfully or have not been erased when it should have been.