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Privacy Policy

This privacy policy is effective as of May 24, 2018

Purpose of this Privacy Policy

At LXRandCo, we are committed to protecting your personal information and to being transparent about the information we hold about you. Using personal information allows us to develop a better understanding of our customers, and in turn to provide you with the best customer experience possible.

The purpose of this policy is to give you a clear explanation about how we collect and process your personal information through your use of our website and your interactions at our retail stores, including any data you may provide when making a product purchase or subscribing to our newsletter.

We will use the information that we collect about you in accordance with:

  • The EU General Data Protection Regulation (Regulation EU 2016/679), (‘GDPR’) which becomes effective May 25, 2018
  • The Canadian Personal Information Protection and Electronic Documents Act (PIPEDA) of Canada

This policy explains:

  1. Who we are
  2. Information we may collect about you
  3. How we collect your data
  4. How we may use your information
  5. Disclosure of your details to third parties
  6. Security of your personal information
  7. Data retention
  8. Your legal rights
  9. Notification of changes to our privacy policy
  10. Contact details and further information

If you have any questions, please contact the Data Protection Officer (DPO) at LXRandCo using the contact details at the end of this policy.

Who we are

LXRandCo is a vintage luxury retailer founded in 2010. Today, LXRandCo has over 150 stores in Canada, United-States, Germany, United-Kingdom, Belgium and in the Netherlands. It is also operating the website www.lxrco.com. Its head office is located in Montreal, Quebec, Canada.

Information we may collect about you

Personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed, i.e. anonymous data.

We may collect, use, store and transfer different kinds of personal information about you which we have grouped together as follows:

  • Identity Data includes first name, last name, title, username or similar identifier, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes payment card details.
  • Transaction Data includes details about payments from and to you and other details of products and services you have purchased from us or sold to us.
  • Technical Data includes internet protocol (IP) address, your login data, 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.
  • Profile Data includes your username and password, purchases, returns, cancellations of appraisals made by you, your preferences, contacts with our customer support, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. This also includes us making a note of conversations we have had with you in person and/or communications you sent to LXRandCo. This helps us to manage our relationship with you and ensures you only receive communications from us that are relevant and timely.
  • Job Applicant Data includes career history, education, and any data submitted by you to us through a job application on our careers page.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal information but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How we collect your data

We collect different information about you in a number of ways:

Information you give us

When you create an account on our website, purchase a product, sign up to our newsletter, complete a customer information card (CIC) in store, give us feedback, contact our customer care or make an appraisal request, we will store the personal information you give to us such as your name, email address, postal address, telephone number and card details. We will also keep a record of your purchases, appraisals (sell your bag page) and communications with us.

Automated technologies or interactions

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

Information from third parties

We occasionally receive information about you from third parties as set out below:

  1. Analytics providers such as Google
  2. Advertising networks such as Facebook
  3. Search information providers such as Google AdWords
  4. Retail and affiliate partners for fulfilling web orders such as c21stores.com

How we may use your information

We will only use your personal information when the law allows us to.

Most commonly, we will use your personal information in the following circumstances:

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.
  • Where we have your explicit consent before using your personal information in that specific situation. However, generally we do not rely on consent as a legal basis for processing your personal information and you have the right to withdraw consent to marketing at any time by contacting us. You will find the relevant contact details at the end of this policy.

Purposes for which we will use your personal information

We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Please note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your information. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis oflegitimate interest

To register you as a new customer

(a) Identity
(b) Contact

(a) (b) Performance of a contract with you

To process and deliver your purchase

(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications

(a) Performance of a contract with you
(b) Necessary for our legitimate interests

To process and buy a product you appraise with us (through the sell your bag form)

(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications

(a) Performance of a contract with you
(b) Necessary for our legitimate interests

To manage our relationship with you which will include:
(a) Notifying you about changes to our terms of use or privacy policy
(b) Asking you to leave a review or take a survey

(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications

(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw or complete a survey

(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications

(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/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)

(a) Identity
(b) Contact
(c) Technical

(a) (c) Necessary for our legitimate interests (for 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)
(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical

(a) (b) (c) (d) (e) (f) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing and communications with you, customer relationships and experiences

(a) Technical
(b) Usage

(a) (b) Necessary for our legitimate interests (to define types of customers for our products and 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 goods or services that may be of interest to you

(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile

(a) (b) (c) (d) (e) Necessary for our legitimate interests (to develop our products/services and grow our business)

To receive and analyze your job application made

(a) Identity
(b) Contact
(c) Job Applicant

(a) (b) (c) Necessary for our legitimate interest (to analyze your job application, and contact you for an interview)

Marketing communications

We aim to communicate with you about the work that we do in ways that you find relevant, timely, respectful, and never excessive. To do this, we use data that we have stored about you, such as which products you purchased in the past, as well as any contact preferences you may have told us about.

We use our legitimate organisational interest as the legal basis for communications by post and email. We will give you an opportunity to opt out of receiving electronic communications in every marketing email that we send you. Alternatively, you can use the contact details at the end of this policy.

As part of our service to you, we may contact you by email or telephone to provide essential information related to your purchase and visit.

You have the right to object to any of this processing at any time. If you wish to do this, please use the contact details at the end of this policy.

Disclosure of your details to third parties

There are certain circumstances under which we may disclose your personal information to third parties. These are as follows:

  • To our service providers who process data on our behalf and on our instructions, for example, our email service provider. We require all third parties to respect the privacy of your personal information and to treat it in accordance with the law, including GDPR compliance. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
  • Where we are under a duty to disclose your personal information in order to comply with any legal obligation (for example to government bodies and law enforcement agencies).

We do not sell personal information to third parties for any purpose.

Security of your personal information

Your credit card information

When you use your credit card to purchase from us, we will ensure that this is carried out securely and in accordance with the Payment Card Industry Data Security Standard (PCI-DSS). We do not store any credit card numbers nor your 3 or 4-digit security code in our systems and none of our staff members can see your card number.

Security of your personal information

We have put in place appropriate safeguards (both in terms of our procedures and the technology we use) to keep your personal information as secure as possible. We will ensure that any third parties we use for processing your personal information do the same and that they will only process your personal information on our instructions. The third parties will also be subject to a duty of confidentiality.

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.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal information, as follows:

a) Request access to your personal information

You have a right to request a copy of the personal information that we hold about you. Please use the contact details at the end of this policy if you would like to exercise this right, or any of the rights listed below.  If you are a European citizen and consider our use of your personal information to be unlawful, you have the right to lodge a complaint.

b) Request correction of your personal information

You have the right to request that we correct the personal information we hold about you, although we may need to verify the accuracy of the new information you provide to us. Please use the contact details at the end of this policy if you would like to exercise this right.

c) Request erasure of your personal information (right to be forgotten)

You have the right to request that we delete or remove personal information where there is no good reason for us continuing to process it. Please note that we may not always be able to comply with your request for erasure if there are specific legal reasons, which will be notified to you at the time of your request.

d) Object to processing of your personal information

You have the right to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object 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.

e) Request restriction of processing your personal information

You have the right to request that we suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if 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 data but we need to verify whether we have overriding legitimate grounds to use it.

f) Request transfer of your personal information

You have the right to request that the personal information we hold about you is transferred to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

g) Right to withdraw consent

In circumstances where we are relying on your consent to process your personal data, you have the right to withdraw your consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Please also note the following:

No fee usually require

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from yo

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within 30 days. Occasionally it may take us up to 60 days 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.

Notification of changes to our Privacy Policy

This privacy policy may change from time to time. We will always communicate any changes to our customers where we have accurate contact details and where they would expect to receive communications from LXRandCo. Please visit this section of our website periodically in order to keep up to date with changes in our privacy policy.

Contact details and further information

Please get in touch with us if you have any questions about any aspect of this privacy policy, and in particular if you would like to object to any processing of your personal information that we carry out for our legitimate organisational interests.

Please also contact us if you have any questions about the information we hold about you, or to change your contact preferences with us:

Email us: privacy@lxrco.com

Write to us:

Canada:

Europe:

LXRandCo – Data Protection Officer
40 Jean-Talon Ouest
Montreal QC, H2R 2W5
Canada

privacy@lxrco.com

LXRandCo – Data Protection Officer
Amtsgericht Köln, HRB 87789, Sitz Köln
c/o avocado rechtsanwälte, spichernstraße 75-77, 50672 Köln
Germany

privacy@lxrco.com

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