Privacy Policy
Hello! We figure you're here because you want to know how we look after your information when you use our website or services. Our lawyers tell us that we have to give you loads of detail, so we’ve set out below a list of the key points which you can click on for the detail.
1. WHO WE ARE
1.1 We are Living Elite, which is a trading name of ManageWell Properties Limited, company number 14982267 and with registered office at 124 City Road, London EC1V 2NX (Living Elite, us, we).
1.2 We are responsible for looking after information we collect from you, keeping it safe and using it lawfully. If you feel there's a problem with how we are doing that, please contact us here: hello@livingelite.co.uk.
1.3 Our website may provide links to third party websites – we are not responsible for these and this policy does not apply to them.
2. WHAT INFORMATION WE COLLECT AND USE
2.1 The information we collect and use falls into various categories:
(a) identity - first name, last name, username or similar identifier, title, gender, date of birth, passport photo and information;
(b) contact - email address, billing address, delivery address and telephone numbers;
(c) financial - payment card or bank account details;
(d) transaction - services or products purchased from us and payments made to us;
(e) technical - IP address, login data, web browser type and version, time zone setting and location, browser plug-in types and versions, operating system and other specifications of devices used to procure our services or products or access our website;
(f) profile - username and password, orders, purchases, feedback, preferences, interests and survey responses;
(g) usage - how our website, services or products are used, including a list of URLs comprising a referring website and the website you exit to; and
(h) marketing and communications – your marketing and communication preferences.
2.2 We will only collect or use the sort of personal information that is considered sensitive (being race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, criminal convictions, information about your health, genetic or biometric data) with specific express consent from you.
3. WHERE WE GET YOUR INFORMATION
3.1 Most of the information we collect about you is provided by you when you (i) make an enquiry with us, (ii) use our services or buy our products, (iii) make payments to us, (iv) send us feedback or any other written communications, (v) answer surveys or enter a competition or promotion through a social media channel.
3.2 We also receive information about you indirectly when you use our platforms.
4. WHAT WE DO WITH YOUR INFORMATION
4.1 Mostly, we use your information to provide you with services and products. The detail below sets out the ways we may use your personal information and the legal bases we rely on to do so, identifying our legitimate interests where appropriate:-
(a) Activity: assess persons who may wish to obtain products or services from us
Type of information: identity and contact
Lawful basis for use:
• performance of a contract with you
• necessary for our legitimate interests (promoting or providing our products and services to you or your organisation)
(b) Activity: register you or an entity you represent as a new customer
Type of information: identity and contact
Lawful basis for use:
• performance of a contract with you
• necessary for our legitimate interests (promoting or providing our products and services to you or your organisation)
(c) Activity: perform our contractual obligations to you or enforce your contractual obligations to us including: (i) managing payments, fees, and charges; and (ii) collecting and recovering money owed to us
Type of information: identity, contact, financial and transaction
Lawful basis for use:
• performance of a contract with you
• necessary for our legitimate interests (to recover debts due)
(d) Activity: manage our relationship with you, including: (i) notifying you about changes to our terms of business or policies; (ii) contacting you about products or services we provide to you; and (iii) asking you to leave a review or take a survey
Type of information: identity, contact, profile, marketing and communications
Lawful basis for use:
• performance of a contract with you
• necessary to comply with a legal obligation
• necessary for our legitimate interests (to keep our records updated and to study how customers use our products and services)
(e) Activity: administer and protect our business including: (i) financial risk assessment, preventing money laundering, fraud or other wrongdoing; (ii) contacting credit reference agencies and making credit related decisions; (iii) troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data
Type of information: identity, contact, technical
Lawful basis for use:
• 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)
• necessary to comply with a legal obligation
(f) Activity: use data analytics to improve our products, services, website, marketing, customer relationships and experiences
Type of information: technical, usage
Lawful basis for use:
• necessary for our legitimate interests (to define types of customers for our products and services, to keep our platforms updated and relevant, to develop our business and to inform our marketing strategy)
(g) Activity: make suggestions and recommendations to you about products or services that may be of interest to you
Type of information: identity, contact, technical, usage, profile, marketing and communications
Lawful basis for use:
• necessary for our legitimate interests (to develop our products / services and grow our business)
4.2 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. 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.
4.3 Our legitimate interests include the following activities so long as we do them in a way that doesn’t unfairly affect your privacy:
• supplying services to you;
• personalising communications or content within emails or on our website;
• understanding customer behaviour, activities, preferences, and needs;
• improving existing and developing new products and services;
• promoting, marketing, and advertising our products and services;
• protecting customers, employees, and other individuals and maintaining their safety, health, and welfare;
• preventing, investigating, and detecting crime, fraud, bullying, harassment, discriminatory or other anti-social behaviour and taking action against perpetrators, including working with law enforcement agencies;
• protecting our business, its customers, and partners, by taking appropriate legal action against third parties who have committed criminal acts, or breach their legal obligations to us; and
• fulfilling our duties to our customers, partners, colleagues, shareholders, and other stakeholders.
4.4 We don’t generally ask you to consent to our use of your information except for sending you marketing. For the delivery of direct marketing to you via e-mail, we’ll need your consent, whether via an opt-in or soft-opt-in:
(a) a soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (e.g. you have contacted us to ask us for more details about a particular product or service, and we are marketing similar products or services). Under “soft opt-in” consent, we will take your consent as given unless you opt-out; and
(b) for other types of e-marketing, we are required to obtain your explicit consent - that is, you need to take positive and affirmative action when consenting.
If you are not satisfied about our approach to marketing, you have the right to withdraw consent at any time.
5. WHO WE SHARE YOUR INFORMATION WITH AND WHY
5.1 We may share your information with certain third parties, being those who provide us with (i) our IT infrastructure, (ii) banking, legal, accounting or consultancy services, (iii) payment processing for services or products you purchase from us, (iv) services across our group (provided by other group companies or affiliates) or (v) services as subcontractors. We do not transfer your personal information outside the EEA.
5.2 We have agreements in place to require such third parties to respect the privacy and security of your information. They are not allowed to use your information for their own purposes but only for the purposes we have specified and in accordance with our instructions.
5.3 If we sell, transfer or merge parts of our business or if we acquire or merge with other businesses, we will share your information with the new owner who will use it in accordance with this privacy policy.
6. HOW WE STORE AND HOW LONG WE KEEP YOUR INFORMATION
Your information is stored securely and we only keep your information for as long as we need it - either for the purpose for which we collected it or where we need it to comply with any legal, regulatory, tax, accounting or reporting requirements.
7. YOUR RIGHTS IN RELATION TO YOUR INFORMATION
As you’ll have gathered, we’re keen on you knowing how you can control use of your personal information. The law gives you various rights here - you can:
(a) request access – to information we hold about you - we will not charge you for this, unless your request is "manifestly unfounded or excessive". We may refuse your request in a limited set of circumstances where that is legally permitted but if we do so we will tell you the reasons why;
(b) request correction – of any incomplete or inaccurate information we hold about you, though we may need to verify the accuracy of the new information you provide to us;
(c) request erasure – of information we hold about you where there is no good reason for us continuing to process it;
(d) object – to us using information we hold about you where we are relying on a legitimate interest and there is something about your particular situation which makes you feel it unfairly affects your privacy;
(e) restrict – our use of information we hold about you by having us temporarily suspending its processing:
(i) if you want us to establish if such information is accurate;
(ii) where our use of the information is unlawful, but you do not want us to erase it;
(iii) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; and
(iv) where you have objected to our use of your information, but we need to verify whether we have overriding legitimate grounds to use it.
(f) request transfer – of information we hold about you (to you or a third party) in a structured, commonly used, machine-readable format. Note that this right only applies to personal information which you initially provided consent for us to use or where we used the information to perform a contract with you.
(g) withdraw consent – to our continued use of information we hold about you where we are relying on consent for such use (this will not affect the lawfulness of anything we did before you withdraw your consent). If you do so, we may not be able to provide certain products or services to you and we will tell you if this is the case at the time.