Privacy Policy
Welcome to The De Vinci Lifestyle Privacy Policy
The De Vinci Lifestyle respects your privacy and is committed to protecting your personal
data. This privacy policy will inform you as to how we process and look after your personal
data when you visit our website (regardless of where you visit it from).
It also tells you about your privacy rights and how the law protects you.
Please also use the Glossary to understand the meaning of some of the terms used in this
privacy policy.
This privacy policy aims to give you information on how The De Vinci Lifestyle collects and
processes your personal data through your use of this website, including any data you may
provide through this website when you sign up to our newsletter, purchase any products or
services or take part in a prize draw or 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 policy together with any other privacy policy or fair
processing policy 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 policy supplements other notices and privacy policies and is not intended to
override them.
The De Vinci Lifestyle is the controller and responsible for your personal data (collectively
referred to as “The De Vinci Lifestyle, “we”, “us” or “our” in this privacy policy).
We have appointed a data privacy manager who is responsible for overseeing questions in
relation to this privacy policy. If you have any questions about this privacy policy, including
any requests to exercise your legal rights, please contact the data privacy manager using the
details set out below.
If you have any questions about this privacy policy or our privacy practices, please contact
our data privacy manager in the following ways:
Full name of legal entity: The De Vinci Lifestyle
Name of data privacy manager: Georgia Emm
Email address: *****
Postal address: 84 The Hundred Romsey Hampshire ****
You have the right to make a complaint at any time to the Information Commissioner’s
Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We
would, however, appreciate the chance to deal with your concerns before you approach the
ICO so please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated on
12/12/2023.
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.
This website may include links to third-party websites, plug-ins and applications. Clicking on
those links or enabling those connections may allow third parties to collect or share data
about you. We do not control these third-party websites and are not responsible for their
privacy statements. When you leave our website, we encourage you to read the privacy
policy of every website you visit.
1.
1. 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 as follows:
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Identity Data includes first name, last name, username
or similar identifier, and date of birth.
Contact Data includes billing address, email address
and telephone numbers.
Financial Data includes none – our payment provideR
Cashflows https://www.cashflows.com/legal/privacy-
policyare the financial data controllers.
Transaction Data includes details about payments to
and from you and other details of products and services
you have purchased from 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 this website.
Profile Data includes your username and password,
and purchases or orders made by you.
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.
We also collect, use and share Aggregated Data such as statistical or demographic data for
any purpose. Aggregated Data could be derived from your personal data but is not considered
personal data in law as this data will 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 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.
We may collect the minimum amount of personal data to enable you to enter into any prize
draw and competition and allow us to run the promotion. If you are a winner, it may be
necessary to collect more detailed information from you in order to award your prize to you.
You will be notified of this at the time we notify you if you have won.
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 goods
or services or to enter you into a competition). In this case, we may have to cancel a product
or service you have with us or refuse your entry to a competition. We will notify you if this is
the case at the time.
1.
1. How is your personal data collected?
We use different methods to collect data from and about you including through:
o
Direct interactions. You may give us your Identity and
Contact by filling in forms or by corresponding with us
by post, phone, email or otherwise. This includes
personal data you provide when you:
our day to day business dealings in
providing our competition services to you;
filling in forms or by corresponding with us
by post, phone, email or otherwise;
if you complete a survey or provide us with
feedback;
as you interact with our website, we may
automatically collect data about your
equipment, browsing actions and patterns.
We collect this personal data by using
cookies, server logs and other similar
technologies;
by using publicly accessible sources; and/or
via third parties such as analytics providers
and/or your bank or building society or
other financial institutions when you pay
for our services.
1.
1. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use
your personal data in the following circumstances:
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Where we need to perform the contract we are about to
enter into or have entered into with you. (A legally
binding contract is formed between us when you
purchase goods or services from us or you enter into a
competition.)
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 obligation.
To find out more about the types of lawful basis that we will rely on to process your personal
data, please see the Glossary below.
Generally, we do not rely on consent as a legal basis for processing your personal data
although we will get your consent before sending third party direct marketing
communications to you via email or text message. You have the right to withdraw consent to
marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all 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.
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. 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 of legitimate interest
To Register you as a new customer (a) Identity
(b) Contact
Performance of a contract with you
To process and deliver your order including
(a) Manage payment, fees and charges
(b) Collect and recover money owed to use
(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 recover debts due to us)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms 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 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, competition 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 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) 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
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, customer relationships and
experiences
(a) Technical
(b) Usage
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
Necessary for our legitimate interests (to develop our products/services and grow
our business)
(e) Profile
(f) Marketing and
Communications
If you are the winner of the competition you will be invited to participate in publicity
exercises relating to the competition. Your participation is not compulsory but would be
greatly appreciated by us. If you do not wish to participate your participation in the
competition or chances of winning will not be affected in any way.
However, if you do not wish to participate in any publicity and decline to be named as the
winner, we may still have to provide your details to the Advertising Standards Authority
(ASA) as proof that the competition has been properly administered and the prize awarded.
This is a legal requirement we must comply with. If you require detail of how the ASA will
use and process your personal data, please let us know.
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly
around marketing and advertising.
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, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from
us or purchased goods or services from us, entered a competition or prize draw and you have
not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third
party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by
following the opt-out links on any marketing message sent to you or by contacting us at any
time.
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/service purchase, warranty registration, product/service
experience or other transactions.
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.
1.
1. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the
table “Purposes for which we will use your personal data” above.
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1.
External Third Parties as set out in the Glossary.
Specific third parties listed in the table “Purposes for
which we will use your personal data” above.
Third parties to whom we may choose to sell, transfer
or merge parts of our business or our assets.
Alternatively, we may seek to acquire other businesses
or merge with them. If a change happens to our
business, then the new owners may use your personal
data in the same way as set out in this privacy policy.
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.
1.
1. International transfers
Many of our external third parties are based outside the UK so their processing of your
personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of
protection is afforded to it by ensuring at least one of the following safeguards is
implemented:
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We will only transfer your personal data to countries
that have been deemed to provide an adequate level of
protection for personal data.
Where we use certain service providers, we may use
specific contracts approved for use in the UK which
give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when
transferring your personal data out of the UK.
1.
1. 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.
1.
1. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the
purposes we collected it for, including for the purposes of satisfying any legal, regulatory,
tax, accounting or reporting requirements. We may retain your personal data for a longer
period in the event of a complaint or if we reasonably believe there is a prospect of litigation
in respect to our relationship with you.
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,
regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available in our
retention policy which you can request from us.
In some circumstances you can ask us to delete your data: see “Your legal rights” below for
further information.
In some circumstances we will anonymise your personal data (so that it can no longer be
associated with you) for research or statistical purposes, in which case we may use this
information indefinitely without further notice to you.
1.
1. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your
personal data.
If you wish to exercise any of these rights, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (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 could refuse to comply with your request in these
circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and
ensure your right to access your personal data (or to exercise any of your other rights). This is
a security measure to ensure that personal data 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 one month. Occasionally it could take us
longer than a month 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.
1.
1. 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 service/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 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 obligation means processing your personal data where it is necessary
for compliance with a legal obligation that we are subject to.
THIRD PARTIES
External Third Parties
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Service providers acting as processors based in the
United Kingdom who provide IT and system
administration services.
Professional advisers acting as processors or joint
controllers including lawyers, bankers, auditors and
insurers based in the United Kingdom who provide
consultancy, banking, legal, insurance and accounting
services.
HM Revenue & Customs, regulators and other
authorities such as the Advertising Standards Authority
acting as processors or joint controllers based in the
United Kingdom who require reporting of processing
activities in certain circumstances.
Marketing providers such as Text Global Limited and
Mailchimp are used for marketing campaigns with the
customers approval.
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:
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If you want us to establish the data’s accuracy.
Where our use of the data is unlawful but you do not
want us to erase it.
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.
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 or services to you. We will advise you if this is the case at the time you withdraw
your consent.