1. INTRODUCTION

1.1 Important information and who we are

Welcome to LVS Hub Limited’s Privacy and Data Protection Policy (“Privacy Policy”). At LVS Hub Limited (“we”, “us”, or “our”) we are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation (“GDPR”), the Data Protection Act 2018 and all other mandatory laws and regulations of the United Kingdom.

This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data.

The individuals from which we may gather and use data can include:

1. Customers
2. Suppliers
3. Business contacts
4. Employees/Staff Members
5. Third parties connected to your customers

and any other people that the organisation has a relationship with or may need to contact.

This Privacy Policy applies to all our employees and staff members and all Personal Data processed at any time by us.

1.2 Your Data Controller

LVS Hub Limited is your Data Controller and responsible for your Personal Data. We are not obliged by the GDPR to appoint a data protection officer and have not voluntarily appointed one at this time. Therefore, any inquiries about your data should either be sent to us by email to [email protected] or by post to 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom.

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.

1.3 Processing data on behalf of a Controller and processors’ responsibility to you

In discharging our responsibilities as a Data Controller we have employees who will deal with your data on our behalf (known as “Processors”). The responsibilities below may be assigned to an individual or may be taken to apply to the organisation as a whole. The Data Controller and our Processors have the following responsibilities:

• Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR (see 2.2 below for more information);
• Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;
• Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data;
• Obtain the prior specific or general authorisation of the Controller before engaging another Processor;
• Assist the Controller in the fulfilment of the Controller's obligation to respond to requests for exercising the data subject's rights;
• Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller;
• Maintain a record of all categories of processing activities carried out on behalf of a Controller;
• Cooperate, on request, with the supervisory authority in the performance of its tasks;
• Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller; and
• Notify the Controller without undue delay after becoming aware of a Personal Data Breach.

2. LEGAL BASIS FOR DATA COLLECTION

2.1 Types of data / Privacy policy scope

“Personal Data” 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 below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:

• Profile/Identity Data: This is data relating to your first name, last name, gender, date of birth.
• Contact Data: This is data relating to your phone number, addresses, email addresses, phone numbers.
• Marketing and Communications Data: This is your preferences in receiving marketing information and other information from us.
• Billing Data: This is information relating to your debit and credit card information such as the name attached to your payment details and your billing address.
• Financial Data: These are your banking details e.g. your account number and sort code.
• Transactional Data: This is information of details and records of all payments you have made for our services or products.
• Technical Data: This is your IP address, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to engage with us.
• Usage Data: information about how you use our website, products and services.

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.