Data Protection
Contact Details
Changes to Privacy Policy
Third Party Links
Legal Basis for use of data
Personal Info we collect
Uses made of Personal Info
Disclosure of Personal Info
How we use Personal Info
Direct marketing options
Safeguarding
Data Retention
Your Legal Rights
Opting Out
Our use of Cookies
Cookie Settings
Changes to Privacy & Cookies
Contact & Address details
This Privacy and Cookies Policy (the "Policy") applies to the website https://raffolux.com (the “Website”) and the Raffolux App (the "App"), both of which are run by Raffolux Ltd ("Raffolux"), whose registered office address is at Raffolux Ltd, 4 Ravey Street, London, EC2A 4QP (company number 10962686). All references in this Policy to "we", "us", and "our" are to Raffolux.
Raffolux recognises the importance of honest and responsible use of your personal information, and we are committed to protecting and respecting your privacy. This Policy explains how Raffolux collects, uses and discloses personal information about you when you visit the Website or the App, and when you contact Raffolux, whether by e-mail, post, fax or telephone using the contact options on the Website and App. The information you provide to us through the Website and the App will initially be collected by Raffolux, but may then be shared with other companies to the extent that it is necessary to do so for Raffolux to operate effectively.
It is important to Raffolux that you feel completely comfortable in visiting and using the Website and the App.
Our website uses information which may involve the use of cookies and Web beacons. Please see the "Cookies" section below for more information.
This website is not intended for children and we do not knowingly collect data relating to children.
For the purposes of the Data Protection Act 2018 (the "Act") and the General Data Protection Regulation 2016/679 (the "GDPR"), the data controller is Raffolux.
We have appointed a data protection officer (DPO) 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 DPO using the details set out below.
If you have any questions about this privacy policy or our privacy practices, please contact our DPO:
Name: Zion Chetram
Email address:zion@raffolux.com
Postal address: Raffolux Ltd, 4 Ravey Street, London, EC2A 4QP
Telephone number: 02039 297496
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator 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.
We keep our privacy policy under regular review. This version was last updated in May 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.
The legal basis on which Raffolux relies to process your personal information includes:
• On some occasions, Raffolux processes your data with your consent (for example, when you agree that Raffolux may place cookies on your device or process or share information that you input into our website).
• On other occasions, Raffolux processes your data when we need to do this to fulfil a contract with you (for example, if you win a prize in a competition that Raffolux promoted or where we are required to do this by law, e.g. to comply with record keeping obligations).
• Raffolux also processes your data when it is in Raffolux’s legitimate interests to do this, and when these interests are not overridden by your data protection rights (including, for example, when Raffolux shares data with our affiliates).
In most cases, the information that Raffolux processes about you is required to deal with your request or registration, or is required by law, or is necessary for the exercise of Raffolux’s legitimate business interests and needs, in which case special care is taken to safeguard your rights and to ensure any such use is proportionate.
Raffolux may also convert personal information into anonymous data and use it (normally on an aggregated statistical basis) for research and analysis to improve Raffolux’s performance.
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).
If you want to contact Raffolux or to use certain facilities we provide on the Website, you will need to provide us with some additional personal information so that we can liaise with you and deal with your request, query or application. If you do choose to provide Raffolux with your personal information, Raffolux will collect that information for our own use and for the purposes described in this Policy.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes first name, last name, 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 bank account and payment card details.
• Transaction Data includes details about payments to and from you.
• 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, purchases or orders made by you, preferences, 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 information will be collected primarily from you as information voluntarily provided to us, but we may also collect it where lawful to do so from (and combine it with information from) public sources, third party service providers, individuals whom you have indicated have agreed for you to provide their personal information, government, tax or law enforcement agencies, and other third parties. We may also collect personal information about you from your use of other company services.
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 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.
Raffolux may use information about you for purposes described in this Policy or disclosed to you on our Website and App or with our services. For example, we may use information about you for the following purposes, all of which we believe to be in our legitimate business interests:
• to operate competitions promoted on the Website and App;
• to respond to and/or deal with any request or enquiry you may raise;
• to improve our products and services and to ensure that content on the Website and App is presented in the most effective manner for you and for your device;
• to administer the Website and App;
• for internal record keeping;
• to contact you (directly, either by Raffolux or through a relevant partner or agent) by e-mail or phone for the above reasons;
• subject to your consent where required under applicable laws, to carry out direct marketing, targeting through paid marketing, and/or e-mail marketing that you have requested;
• to perform any contract Raffolux has with you; for compliance with legal, regulatory and other good governance obligations; and
• subject to your consent when entering a charity prize draw or raffle, to share your personal data via secure transfer to any specified third party organisations.
Your personal information will be made available for the purposes mentioned above (or as otherwise notified to you from time to time), on a 'need-to-know' basis and only to responsible management, human resources, accounting, legal, audit, compliance, information technology and other Raffolux staff who properly need to know these details for their functions within Raffolux. Please note that certain individuals who will see your personal information may not be based at Raffolux or in your country of residence (please see below).
We may share personal information within Raffolux as needed for reasonable management, analysis, planning and decision making, including in relation to taking decisions regarding the expansion and promotion of our service offering and for use by Raffolux for the other purposes described in this Policy.
Your personal information may also be made available to third parties (within or outside Raffolux) providing relevant services under contract to Raffolux (see below for further details), such as credit and debit card processors, auditors and compliance managers, provider or call centres and IT hosting and IT maintenance providers. These companies may use information about you to perform their functions on our behalf. Subject to your consent when entering a charity prize draw or raffle, Raffolux may also share your personal data via secure transfer to any specified third party organisations. Those organisations will process that data for their own respective purposes, and will become the controller of that personal data. Raffolux has put in place various security and data privacy measures, inclusive in scope of such third parties, in order to protect personal information and shall seek to comply with applicable legal requirements.
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA that work for us or for one of our providers. This may include staff engaged in, among other things, the fulfilment of any contract with you, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.
We may disclose specific information upon lawful request by government authorities, law enforcement and regulatory authorities where required or permitted by law and for tax or other purposes. Personal information may also be released to external parties in response to legal process, and when required to comply with laws, or to enforce our agreements, corporate policies, and terms of use, or to protect the rights, property or safety of Raffolux, our employees, agents, customers, and others, as well as to parties to whom you authorise Raffolux to release your personal information.
We will not sell your personal information to any third party other than as part of any restructuring of Raffolux or sale of the business.
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.We may share personal information within Raffolux as needed for reasonable management, analysis, planning and decision making, including in relation to taking decisions regarding the expansion and promotion of our service offering and for use by Raffolux for the other purposes described in this Policy.
| 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 payments, fees and charges (b) Collect and recover money owed to us |
(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 of 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, 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 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 (e) Profile (f) Marketing and Communications |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Raffolux may wish to provide you with information about new products, services, promotions and offers which may be of interest to you, and may invite you to take part in market research or request feedback on our products and services. This communication may occur by e-mail, telephone, post, social media or SMS. We will obtain your consent and advise you of how to opt-out of receiving such communications where we are required to do so in accordance with applicable law.
Raffolux takes reasonable steps to maintain appropriate physical, technical and administrative security to help prevent loss, misuse, unauthorised access, disclosure or modification of personal information. While we take these reasonable efforts to safeguard your personal information, we cannot guarantee the security of any personal information you disclose online. You accept the inherent security implications of dealing online and will not hold us responsible for any breach of security unless such breach has been caused by the specific negligence of Raffolux, or our agents.
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.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
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.
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:
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.
If you wish to do so, or to notify Raffolux of a change in your details, please contact support@raffolux.com and/or post to Raffolux Ltd, 4 Ravey Street, London, EC2A 4QP.
There are exceptions to these rights, however. For example, access to personal information may be denied in some circumstances if making the information available would reveal personal information about another person, or if we are legally prevented from disclosing such information. In addition, we may be able to retain data even if you withdraw your consent, where we can demonstrate that we have a legal requirement to process and store your data.
If you have a question about the use of your personal information, or wish to file a complaint about it, please contact us using the contact details set out above.
Finally, if you have unresolved concerns, you also have the right to complain to the data protection authorities.
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences OR 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.
We use cookies for certain areas of the Website and App. Cookies are small data files stored on your hard drive by a website. Cookies help us improve the Website and App, and your experience of them. We use cookies to see which areas and features are popular and to count visits to our websites, to recognise you as a returning visitor, to assist us with our marketing and to tailor your experience of the Website and/or App according to your preferences. Overall, cookies help us provide you with a better Website and App, by enabling us to monitor which pages you find useful and which you do not. We may also use cookies for targeting and/or advertising purposes. We may use Web beacons on our Website and App, or in our e-mails. Web beacons are electronic images that may be used to deliver cookies, count visits, understand usage of group websites and to tell if an e-mail has been opened and acted upon. Further details about cookie purposes and types are below. To delete or block cookies through your browser settings at any time, and for more general information about cookies including the difference between session and persistent cookies, visit www.allaboutcookies.org.
We also use Google Analytics on the Website and App to collect information about your online activity on the Site, such as the Web pages you visit and the links you click on the Website and App. We use the information to compile reports and to help us improve the Website and App. The cookies collect information in an anonymous form, including the number of visitors to the Website and App, where visitors have come to the Website and App from and the pages they visited.
For more information about the information gathered using Google Analytics please visit http://www.google.com/intl/en/analytics/privacyoverview.html. You can prevent these cookies by selecting the appropriate settings on your browser. If you do this you may not be able to use the full functionality of this Site. You may download and install the Google Analytics Opt-out Browser Add-on available here: http://tools.google.com/dlpage/gaoptout.
We use category 1, 2, 3 and 4 cookies as defined in the International Chamber of Commerce United Kingdom Cookie Guide:
| Cookie name/Type | Duration | Purpose | Category of Cookie as defined in the ICC Cookie Guide |
|---|---|---|---|
| csrftoken | 1 year | This cookie is associated with Django web development platform for python. Used to help protect the website against Cross-Site Request Forgery attacks. | 1 - Strictly necessary cookies |
| __lc_cid | 1 year 1 month 4 days | This is an essential cookie for the website live chat box to function properly. | 3 - Functionality cookies |
| __lc_cst | 1 year 1 month 4 days | This cookie is used for the website live chat box to function properly. | 3 - Functionality cookies |
| __oauth_redirect_detector | Less than a minute | This cookie is used to recognize the visitors using live chat at different times in order to optimize the chat-box functionality. | 3 - Functionality cookies |
| __kla_id | 1 year 1 month 4 days | Klaviyo sets this cookie to collect information on the visitor’s behavior. This information is used for internal analytics and to optimise the website. It also registers if the visitor has subscribed to a news letter. | 2 - Performance cookies |
| _gcl_au | 3 months | Google Tag Manager sets the cookie to experiment advertisement efficiency of websites using their services. | 2 - Performance cookies |
| _ga | 1 year 1 month 4 days | Google Analytics sets this cookie to calculate visitor, session and campaign data and track site usage for the site's analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognise unique visitors. | 2 - Performance cookies |
| _gid | 1 day | Google Analytics sets this cookie to store information on how visitors use a website while also creating an analytics report of the website's performance. Some of the collected data includes the number of visitors, their source, and the pages they visit anonymously. | 2 - Performance cookies |
| _gat_gtag_UA_* | 1 minute | Google Analytics sets this cookie to store a unique user ID. | 2 - Performance cookies |
| _fbp | 3 months | Facebook sets this cookie to display advertisements when either on Facebook or on a digital platform powered by Facebook advertising after visiting the website. | 2 - Performance cookies |
| _gat_UA-* | 1 minute | Google Analytics sets this cookie for user behaviour tracking. | 2 - Performance cookies |
| _uetsid | 1 day | Bing Ads sets this cookie to engage with a user that has previously visited the website. | 2 - Performance cookies |
| _uetvid | 1 year 24 days | Bing Ads sets this cookie to engage with a user that has previously visited the website. | 2 - Performance cookies |
| __adroll | 1 year 1 month | This cookie is set by AdRoll to identify users across visits and devices. It is used by real-time bidding for advertisers to display relevant advertisements. | 4 - Targeting cookies or advertising cookies |
| __adroll_shared | 1 year 1 month | Adroll sets this cookie to collect information on users across different websites for relevant advertising. | 4 - Targeting cookies or advertising cookies |
| MUID | 1 year 24 days | Bing sets this cookie to recognise unique web browsers visiting Microsoft sites. This cookie is used for advertising, site analytics, and other operations. | 4 - Targeting cookies or advertising cookies |
| __adroll_fpc | 1 year | AdRoll sets this cookie to target users with advertisements based on their browsing behaviour. | 4 - Targeting cookies or advertising cookies |
| __ar_v4 | 1 year | This cookie is set under the domain DoubleClick, to place ads that point to the website in Google search results and to track conversion rates for these ads. | 4 - Targeting cookies or advertising cookies |
| fr | 3 months | Facebook sets this cookie to show relevant advertisements by tracking user behaviour across the web, on sites with Facebook pixel or Facebook social plugin. | 4 - Targeting cookies or advertising cookies |
| raffolux_id | 1 year 1 month 4 days | . | 3 - Functionality cookies |
| WZRK_S_W6K-Z97-ZK6Z | 20 minutes | . | 3 - Functionality cookies |
| WZRK_G | 1 year 1 month 4 days | . | 3 - Functionality cookies |
| _cioanonid | 1 year | . | 3 - Functionality cookies |
| theme | never | . | 3 - Functionality cookies |
| _te_ | Length of the user's session | . | 3 - Functionality cookies |
| _cio | 1 day | . | 3 - Functionality cookies |
Our website uses FullStory and the FullStory cookie to collect information that may be personally identifiable, such as pages visited, links clicked, non-sensitive text entered, and mouse moveemnts, as well as information more commonly collected such as the referring URL, browser, operating system, and Internet Protocol ("IP") address. We use publicly available sources to approximate your geographic region and Internet Service Provider based on your IP address. We use the term "Usage Data" to refer to this information about your use of our website that we collect. FullStory's purpose in collecting Usage Data is to better understand how you use our website, monitor for fraud, and more. You can find more information here: www.fullstory.com/legal/acceptable-use and here: https://www.fullstory.com/legal/privacy/ If you wish to prevent all websites using the FullStory Services to be able to record activity, you can opt-out of the FullStory Services. Opting out will create a cookie that tells FullStory to turn off recording on any site which uses the FullStory Services. The cookie is available here.
We will ask for your consent to the use of cookies set out in this Policy when you first access the Website or App, and if we introduce any new cookies to the Website/App. When you first visit the Website and App, a box/banner will appear asking you to agree to the cookies that we set on the Website/App.
You can usually choose to set your browser to warn you when a cookie is being sent or to remove or reject cookies. Each browser is a little different, so look at your browser help menu to learn the correct way to modify your cookie settings. If you choose to remove or reject cookies, it will affect many features or services on our Website and App.
If you agree to cookies from our Website or App by clicking on the "Accept All" button, we will set cookies from all four categories on your device. If you wish to delete the cookies we have set on your device, please refer to your browser help menu.
If you do nothing to indicate your cookie preference for our Website or App (i.e. if you do not click on any button in the cookie box/banner), only category 1 cookies will be set on your device. To modify your cookie settings, please refer to the help menu of your browser.
If you say no to cookies on our Website or App by clicking on the "Reject All" button, we will not set category 2, 3 and 4 cookies on your device. Please note that if you do this you may not be able to use the full functionality of our Site.
You can choose to enable or disable cookies that perform functional, analytics, performance, advertisement and uncategorised functions by clicking the 'Customize' button in the cookie box/banner.
We keep this Policy under regular review. We may change this Policy from time to time by updating this page in order to reflect changes in the law and/or our privacy practices.
We encourage you to check the date of this Policy when you visit the Website or App for any updates or changes. We will notify you of any modified versions of this Policy that might materially affect the way we use or disclose your personal information.
If you have any questions about this Policy, please contact us by e-mail at support@raffolux.com, or by post at:
Raffolux Ltd, 4 Ravey Street, London, EC2A 4QP