We are L’Effet Limited (“we”, “us”, “our”), and we are committed to protecting your privacy. L’Effet Limited is the controller for the purposes of the General Data Protection Regulation (the “GDPR”),a company registered in England and Wales (Company No. 11249501), with its registered office located at 300 Vauxhall Bridge Road, London SW1V 1AA, United Kingdom.
2. Third party websites
3. What information do we collect, and how?
When you interact with us, whether by using our Website or communicating with us, we may collect the following information about you:
• Information you give us: you may give us information about yourself if you use our Website to sign up for an account with L’Effet, claim any rewards for shopping in cash or in loyalty programme miles (“the Incentives”), purchase Experiences, complete any online forms (such as registration forms, competitions, and surveys), opt in to receive our newsletters and special offers, enter a competition or promotion, participate in social media functions connected to our Website, or correspond with us (by email, telephone, instant chat, social media or otherwise).
This information may include your name, address or location, phone number and email address, date of birth, gender, purchase information, shopping preferences, images, financial information (including your credit or debit card details or your PayPal or Alipay account number) and your membership numbers for airline or hotel or loyalty programmes (“Loyalty Programmes”), amongst other information.
• Information we receive from other accounts or sources: we may receive information about you from your other accounts or other websites, including data brokers, our Partners, social media providers like WeChat, Facebook and Twitter, advertising networks and analytics partners, and payment and delivery service providers, amongst others.
By logging in to our mobile applications via social media platforms, or linking your account on our Website to your social media accounts, you are giving us permission to obtain certain information and content from these accounts. The specific types of information that we may obtain depends on your settings for that account or website, and will be subject to their privacy policies.
We may supplement the data you provide to us with data from data append services such as public or social graph data in order to serve you better with content or promotions. We will append this data to our existing customer account information to understand customers’ interests better and to provide more relevant retailer recommendations and advertising. We may append information about you that is publicly available such as, for example, household size, household income, or profession. This information may be associated with your personal information such as name, email address, physical address, or phone number.
You can see more details about the third parties we use in section 6.
• Information our IT systems collect about you: each time you visit the Website, certain information will be created and automatically recorded by our IT systems. That information includes:
• cookies: we’ve set out more details about cookies below, but these small text files can help improve your experience with the Website and make it easier to interact with us. This may include storing your location or language preferences to save you having to re-enter information when returning to a page on our Website or ensuring that stores you wish to visit don’t disappear as you navigate between pages on our Website;
• device information: the information provided by your device will differ depending on which type of device you are using (whether it’s a PC, Mac, iPhone, Android, or otherwise) and the settings on that device, but includes the type of device you have (such as an iPhone® or Samsung Galaxy®), the device’s IP address, the browser you are using, your mobile network provider (for mobile devices), the pages you have visited, your time zone and country location, and crash or download error reports.
4. What do you use my information for?
To provide you with the services we offer, to make our Website work, including administering your account, ensuring your cash or other rewards are credited to the right account and allowing you to purchase Experiences through our Website, and to optimise your experience while using the Website, we need to use the information that we collect in a number of different ways. The key purposes for which we use your information are as follows:
• to provide you with the services we offer, you need to register an account on our Website. Your information (including name, address, phone number, email address and membership information (such as your Loyalty Programme, PayPal®or Alipay®membership number)) will be used so you can claim, and we can process and fulfil, the Incentives you receive for shopping at our Partners’ stores. In cases where you buy Experiences (such as access to fashion shows or participation in a workshop) through our Website, we will also need your financial information (such as debit or credit card details). We may also use your information to communicate with you about your Incentives and Experiences and provide you with customer support when needed. This may require us to provide your information to third parties including our Partners, from whom you are purchasing your Experience, as further set out below;
• to provide you with the correct Incentives in the right amount: whether you have chosen to receive cash or Loyalty Programme rewards, we need to keep a record of your purchases including the date, store, location, time, amount spent and the type of product you have bought so we can credit you with the correct amount and type of Incentive. This also allows us to respond quickly and accurately in the case of any problems you may encounter;
• to provide you with the correct Experience: we need to keep a record of your purchases including the date, supplier, location, time, amount spent and the type of Experience you have bought so we can ensure it is delivered to you as agreed and we can credit you with the correct amount and type of Incentive. This also allows us to respond quickly and accurately in the case of any problems you may encounter;
• to administer, maintain, and optimise our Website, our services and your experience: we want you to have the best experience possible when you interact with us, including using our Website, products and services. To do this, we use your information (including log data, statistical information, and device information) to ensure that the Website and its features and any Wi-Fi networks are functioning correctly, to adapt and customise our Website to match your preferences more closely, and to provide pages specific to your language or location. We may also work with selected third parties to enrich, match or combine some of your information to provide you with customised offers and personalised services;
• to provide you with customer services: if you contact our customer services team or provide us with feedback for any reason, whether by email, phone, chat, or otherwise, we will use your information (including your name, phone number, and email address) to help us categorise the communication, respond to you, and where appropriate, investigate, and resolve any issue or incident that you may have. We may also use your phone number or email address to let you know the status of, or if there are any problems with, your Incentives;
• For advertising and marketing purposes:
Where you have told us you would like to receive marketing communications or when you have earned Incentives by using our Services, unless you tell us otherwise, L’Effet and our Partners will use your personal information (including your name, email address and address) to send you occasional updates, news, and offers via email, post or other forms of media. We may use your information (including supplemental information received from partners that we append to our existing customer information), to tailor these messages to you. You may unsubscribe from email marketing communications by modifying your preferences in your account’s profile management section, or by following the opt-out instructions in the promotional emails we send you;
• to carry out research, analysis, and surveys on your use of our Website, and views: where you have opted in to receiving communications from us, we may use your personal details (including your name, address, email address, and phone number) to send you polls and surveys to find out your views of our Website and services. We may also carry out analysis of, and research into, the ways that you use our Website so we can optimise the Website and your experience. We may use third parties to carry out any research, analysis, and surveys, or to deliver incentives in return for your participation in polls, as further set out below; and
•for your, and our, financial security: for everyone’s safety, we need to ensure that our customers are genuine. To do this, we may use your personal information (including your name, address, and financial information, such as credit or debit card details) to confirm your identity and perform credit check or anti-fraud checks. We may use third party credit reference or fraud prevention agencies to perform these checks, as further set out below, but no formal credit check is performed and your credit rating will not be affected. Please note that we do not sell or give your information without your consent (whether your name, address, emails address, financial information, or otherwise) to any third party.
5. What is our legal basis for using your personal information?
L’Effet Limited will only process your personal information where we have a legal basis to do so. The legal basis will depend on the reason or reasons L’Effet collected or needs to use your information. Under UK data protection laws in almost all cases the legal basis will be:
to administer our contractual obligations to you as a member of L’Effet’s Incentive Programme
when it is in our legitimate interests to use your personal information to operate and improve our business
to process your Incentives, to deliver any Experiences you purchase and otherwise perform that contract which we have with you
to comply with a legal obligation
More information on each legal basis is provided below.
To register and manage your account in our Website, we collect your name, email, password and choice of Loyalty Programme. The legal basis is the performance of a Contract with you.
To deliver Incentives you have earned through our Incentive Programme, we collect your name and your Loyalty Programme membership number or your PayPal®/ AliPay®account number. The legal basis is the performance of a Contract with you.
To deliver to you Experiences you purchase through our website, we collect your name, address and phone number as well as Experience details, like the Experience you are buying, the date, the price and the number of packages you are buying. The legal basis is the performance of a Contract with you.
To collect payment from you we collect your payment information, which comprises the credit/debit card’s number, holder’s name and CVV. The legal basis is the performance of a Contract with you.
To provide you with our customer services (including helping you to solve any issue you have with our services, updating you about any change to our terms of service, or contacting you to know how was your experience with us) we collect your name, email, password and addresses and your contact history with us (including phone records of our conversations. The legal basis is the performance of a Contract with you and our legitimate interests in retaining you as a customer.
To monitor the quality of our customer services, we collect your name, email, password and addresses and your contact history with us. The legal basis is the legitimate interests in running our business.
To administer, maintain and optimise our Website and our services, we collect your device information (such as your device IP address and device type), Cookie identifiers and browsing information. The legal basis is the legitimate interests in running our business.
To perform fraud and credit checks and if we can do business with you, we collect your name; email; addresses; credit/debit card details; browsing history; purchase history; date of birth; gender; device information (such as IP address and device type), any national identifiers (like driver’s license or ID cards) and any publicly available information (like social media profiles or news). The legal basis is the legitimate interests to protect L’Effet Limited and its customers from fraudulent activities and compliance with a legal obligation.
To send you marketing communications and personalised offers, we may collect your Name; Email; Phone Number; Addresses; Date of Birth; Purchase history; Browsing history and behavior; Device information; Shopping preferences; Cookie identifiers; Internal identifiers; Country. The legal basis is the legitimate interest to send you electronic direct marketing of similar products and services to that which you have acquired using our Website or, when such is not applicable, to gain your Consent to send you such marketing.
To manage our Incentive Programme, we may collect your Name; Email; Phone Number; Addresses; Date of Birth; Purchase history; Browsing history and behaviour; Device Information; Shopping preferences; Nickname; Cookie identifiers; Internal identifiers; Country; Spent tier level and Wealth. The legal basis is our legitimate interests in running our business and in improving the shopping experience.
To provide you with personalised recommendations and enhance your experience, we may collect your Name Email; Phone Number; Addresses; Date of Birth; Purchase history; Browsing history and behaviour; Device Information; Shopping preferences; Nickname; Cookie identifiers; Internal identifiers; Country; Spent tier level and Wealth. The legal basis is our legitimate interests in running our business and improving our Website and your experience.
To carry on research, analysis, enquiries and surveys on your use of our website, we collect your Name; Addresses; Email; Device information, legal basis is our legitimate interests in running our business and improve our Website and your experience.
To deliver advertising and retarget advertising of our Services and our Partners’ products and services, we collect your email, cookie identifiers and device information. The legal basis is our legitimate interests in running our business.
To produce aggregated statistical reports, we use your order history, provided that the result of such reports do not identify you. The legal basis is our legitimate interests in running our business and improving our Website.
6. Who do you share my information with?
To provide the Website and our services, we work with a number of carefully selected third parties. To do this, we may share your information with these third parties in the following limited circumstances:
• third party service providers for business purposes: to function properly, we rely on a number of carefully selected third parties to provide us with services and products. These include our Partners from whom you purchase products, Loyalty Programmes who credit you with the rewards you have chosen to receive as your Incentives, anti-fraud and credit check providers to keep us and you secure, analytics companies to enable our marketing, research companies to help us carry out surveys, IT/technology providers to support, maintain and provide our technology and IT infrastructure and others. We permit these companies to use your personal information only to the extent necessary to provide us with their services and products; we do not allow these third parties to disclose or use your information for any other purposes. We have high expectations and requirements of their handling of your personal information and we hold them to these;
• advertisers for marketing purposes: we may provide your information to our advertising and social media partners where they require the data to select and serve relevant adverts about our products and services to you and others;
• third party service providers to enrich data: we may also enrich, match or combine information we hold about you with data from other sources, for instance by sharing some of your personal data with selected business partners. We do this to understand your customer profile and interests better so that we can deliver customised offers and other personalised services;
• to comply with legal requests: on occasion we may be required to liaise with various regulators and law enforcement agencies in a number of different countries, whether as a result of law, a court order, or another legal process. Although we dispute requests where appropriate, in some cases we may have to share your information with the regulators or law enforcement agencies. Where we consider it appropriate, and provided we are not prohibited from doing so by law or court order, we will attempt to notify you of these legal demands; and
• aggregated information with third parties: we may aggregate your information with the information of other customers, creating a dataset of information about the usage of our Website, purchase of products, and other general, grouped information about our customers. Although this dataset is aggregated and anonymised, meaning it cannot identify you as an individual, it provides a valuable insight into the use of our Website and we may therefore share it with select third parties. These parties may include providers of plugins or similar technologies to help measure traffic, our Partnersand other providers to allow them to stock products more accurately, and our investors. Please note that we do not share your information with any third party advertisers or networks for the provision of third party advertising on our Website.
7. Transfers of your personal data
We use technology such as “cookies” to collect information and store your online preferences. Cookies are small pieces of information sent by a web server to a web browser, which allows the server to uniquely identify the browser on each page.
We use the following categories of cookies on our Website
CATEGORY 1: STRICTLY NECESSARY COOKIES These cookies are essential in order to enable you to move around the website and use its features. Without these cookies, services you have asked for such as remembering your login details or shopping basket items cannot be provided.
CATEGORY 2: PERFORMANCE COOKIES These cookies collect anonymous information on how you use our Website. For example, we use Google Analytics cookies to help us understand how customers arrive at our site, browse or use our site and highlight areas where we can improve areas such as navigation, shopping experience and marketing campaigns. The data stored by these cookies does not show personal details from which your individual identity can be established. You may opt out of these cookies using your browser settings but it may affect the performance of our Website.
CATEGORY 3: FUNCTIONALITY COOKIES These cookies remember choices you make such as the country you visit our Website from, the language you select, the country you plan to visit and search parameters such as retailer category. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored, easier to navigate and more helpful. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites. You may opt out of these cookies using your browser settings but it may affect the functionality of our Website.
CATEGORY 4: TARGETING COOKIES OR ADVERTISING COOKIES These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advert as well as help measure the effectiveness of an advertising campaign. The cookies are usually placed by third party advertising networks. They remember the websites you visit and that information is shared with other parties such as advertisers. For example, we may use third party companies to provide you with more personalised adverts when visiting other websites.
CATEGORY 5: SOCIAL MEDIA COOKIES These cookies allow you to share what you’ve been doing on the website on social media such as Facebook and Twitter. These cookies are not within our control. Please refer to the respective privacy policies for how their cookies work. If you want to delete any cookies that are already on your computer, please refer to the help and support area on your Internet browser for instructions on how to locate the file or directory that stores cookies. Information on deleting or controlling cookies is available at www.AboutCookies.org. Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our Website.
To opt out of:
• Google Analytics®cookies across all websites, please visit Google Analytics Opt-out Browser Add-on;
• other third party cookies relating to behavioural advertising, please go to www.youronlinechoices.eu.
Please note that opting out does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted out will no longer deliver adverts tailored to your web preferences and usage patterns, so you may see a greater number of adverts that are irrelevant to you and your preferences.
Keeping you and your personal information secure is very important to us. We take a number of reasonable steps to try to protect the personal information that you provide, including:
• using a Secure Socket Layer (“SSL”) to encrypt the personal data that you send us during the order process (including any financial information such as credit or debit card details);
• requiring you to establish a password to access your account on our Website;
• not keeping details of your credit or debit card that would enable any third party to transact using that credit or debit card (such as your CCV number); and
• regularly monitoring our servers and IT systems for possible vulnerabilities and attacks. Unfortunately, despite this, the transmission of information via the Internet is not completely secure. We cannot guarantee the security of your personal data transmitted to or through our Website, and any such transmission is at your own risk. In particular, please keep in mind that if you voluntarily disclose personal information online in a non-protected environment (such as a message board, shopping list, or in chat areas) then that information can be collected and used by others outside of our or your control.
10. Contact us & accessing personal information
All of the information that we collect, or that you provide to us, is controlled by L’Effet Limited for the purpose of the Data Protection Act 1998 and other applicable local laws. You have various rights under the Data Protection Act 1998 and other applicable local laws, including the right to see all of the personal information we hold about you, to require that we correct any inaccuracies in your personal information, or to object to certain information being stored or used (including to ask us to stop sending your marketing communications).
• by emailing us at email@example.com; or
• by writing to The Legal Department, L’Effet Limited, 300 Vauxhall Bridge, SW1V 1AA, United Kingdom. Please note that we may charge you a small fee for providing a copy of your information, as permitted by law.
You also have a right to complain to your Data Protection Authority. In the UK that Authority is the Information Commissioner whose website address is ico.org.uk. You can contact the Information Commissioner’s Office by telephone on 0303 123 1113.