1. Important information and who we are

Purpose of this privacy notice

This privacy notice provides information on how LSA collects and processes your personal data through your use of this website. This includes any data you may provide through this website when you sign up to our newsletter, purchase a product or take part in a competition.

This website is not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller
LSA International Inc is the controller and responsible for your personal data (referred to as "LSA", "we", "us" or "our" in this privacy notice). We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details: LSA International Inc
Data Protection Officer: Malcolm Foreman
Email address: info@lsa-international.com

Changes to the privacy notice and your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2. The data we collect about you

Personal data, or 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 (anonymous data).

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

Identity data: First name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

Contact Data: Billing address, delivery address, email address and telephone numbers.

Financial Data: Payment details.

Transaction Data: Details about payments to and from you and other details of products you have purchased from us.

Technical Data: 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 this website.

Profile Data: Your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

Usage Data: Information about how you use our website and products.

Marketing and Communications Data: Your preferences in receiving marketing from us and our third parties and your communication preferences.

Aggregated Data: 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 data 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 notice.

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

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products). In this case, we may have to cancel the order you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you, including through:

Direct interactions
You may give us your Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

1. apply for our products;
2. create an account on our website;
3. subscribe to our services;
4. agree for marketing information to be sent to you;
5. enter a competition, promotion or survey; or
6. provide us with feedback.

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, server logs and other similar technologies. Please see our cookie policy for further details.

4. How we use your personal data

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

1. Where we need to perform the contract we are about to enter into or have entered into with you.
2. 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.
3. Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you, in line with GDPR. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we use your personal data:
The table below outlines the ways we plan to use your personal data 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 data for more than one lawful ground depending on the specific purpose for which we are using your data. Contact us if you would like 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.

1. To register you as a new customer

Data Type:
a. Identity
b. Contact

Lawful basis:
Performance of a contract with you


2. To process and deliver your order

Including:
a. Manage payments, fees and charges
b. Collect and recover money owed to us

Data type:
a. Identity
b. Contact
c. Financial
d. Transaction
e. Marketing and Communications

Lawful basis:
a. Performance of a contract with you
b. Necessary for our legitimate interests (to recover debts due to us)


3. To manage our relationship with you

Including:
a. Notifying you about changes to our terms or privacy policy
b. Asking you to leave a review or take a survey

Data type:
a. Identity
b. Contact
c. Profile
d. Marketing and Communications

Lawful basis:
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)

4. To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

Data type:
a. Identity
b. Contact
c. Technical

Lawful basis:
a. 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

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

Data type:
a. Identity
b. Contact
c. Profile
d. Usage
e. Marketing and Communications
f. Technical

Lawful basis:
Necessary for our legitimate interests (to study how customers use our products, to develop them, to grow our business and to inform our marketing strategy)

6. To use data analytics to improve our website, products, marketing, customer relationships and experiences

Data type:
a. Technical
b. Usage

Lawful basis:
Necessary for our legitimate interests (to define types of customers for our products, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

7. To make suggestions and recommendations to you about products that may be of interest to you.

Data type:
a. Identity
b. Contact
c. Technical
d. Usage
e. Profile

Lawful basis:
Necessary for our legitimate interests (to develop our products and grow our business)

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us or purchased products from us and in each case you have not opted out of receiving that marketing.

Opting out

You can ask us to stop sending you marketing messages at any time by contacting us.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase, product experience.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please visit www.lsa-international.com/customer-serivce/cookies

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may need to share your personal data with the parties set out below for the legitimate purposes set out in the table in section 4 above. Including Internal Third Parties and External Third Parties as set out in the Glossary.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. Data retention

How long will you use my personal data for?
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.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

8. Glossary

Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

9. Your legal rights

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to 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.

Request restriction of processing of your personal data. This enables you to ask us to 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.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. 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.

Withdraw consent at any time where we are relying on consent to process your personal data. 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 to you. We will advise you if this is the case at the time you withdraw your consent.