This is the privacy notice of Lustrum Partners Limited. In this document, "we", "our", or"us" refer to Lustrum Partners Limited.
We are company number 12673550, registered in the United Kingdom.
Our registered office is at 1 London Street, Reading, England RG1 4PN.
This privacy notice aims to inform you about how we collect and process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information. It tells you about your privacy rights and how the law protects you.
We are committed to protecting your privacy and the confidentiality of your personal information. Our policy is not just an exercise in complying with the law, but a continuation of our respect for you and your personal information.
We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
Our policy complies with the Data Protection Act 2018 (“Act”) accordingly incorporating the EU General Data Protection Regulation (“GDPR”).
The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data. We do this now, by requesting that you read the information provided at http://www.knowyourprivacyrights.org.
Any personal information we hold about you is stored and processed in accordance with the Act and the GDPR.
Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website (“website” or “Site”).
We may collect, use, store and transfer different kinds of personal data about you. We have collated these into groups as follows:
Your identity: includes information such as first name, last name, title, date of birth, and other identifiers that you may have provided at some time.
Your contact information: includes information such as billing address, delivery address, email address, telephone numbers and any other information you have given to us for the purpose of communication or meeting.
Technical data: includes your internet protocol (IP) address, 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.
Marketing data: includes your preferences in receiving marketing from us; communication preferences; responses and actions in relation to your use of our services.
We may aggregate anonymous data such as statistical or demographic data for any purpose. Anonymous data is data that does not identify you as an individual. Aggregated data may be derived from your personal data but is not considered personal information in law because it does not reveal your identity.
For example, we may aggregate profile data to assess interest in a product or service.
However, if we combine or connect aggregated data with your personal information so that it can identify you in any way, we treat the combined data as personal information and it will be used in accordance with this privacy notice.
Having accurate information about you permits us to provide you with a smooth, efficient, and customised experience. Specifically, we may use information collected about you via the Site to:
• Compile anonymous statistical data and analysis for use internally or with third parties.
• Deliver targeted advertising, newsletters, and other information to you.
• Email you regarding your contact queries.
• Increase the efficiency and operation of the Site.
• Monitor and analyse usage and trends to improve user experience on the Site.
• Notify you of updates to the Site.Offer new products, services, and/or recommendations to you.
• Perform other business activities as needed.
• Request feedback and contact you about your use of the Site.
• Resolve disputes and troubleshoot problems.
• Respond to product and customer service requests.
Special personal information: is data 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.
It also includes information about criminal convictions and offences.
We do not collect any special personal information about you.
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 that contract. In that case, we may have to stop providing a service to you. If so, we will notify you of this at the time.
The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.
If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.
If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
We believe that the four bases of processing below are most likely to be applicable to any use of your personal information by us.
When you create an account on our website, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.
In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.
We may use it in order to:
• verify your identity for security purposes
• provide you with our services
• provide you with suggestions and advice on products, services and how to obtain the most from using our website
We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including job opportunities and our products and services, you provide your consent to us to process information that may be personal information.
Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies.
If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.
We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us contact@lustrumpartners.com. However, if you do so, you may not be able to use our website or our services further.
We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.
Where we process your information on this basis, we do after having given careful consideration to:
• whether the same objective could be achieved through other means
• whether processing (or not processing) might cause you harm
• whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so
For example, we may process your data on this basis for the purposes of:
• record-keeping for the proper and necessary administration of our business
• responding to unsolicited communication from you to which we believe you would expect a response
• protecting and asserting the legal rights of any party
• insuring against or obtaining professional advice that is required to manage business risk
• protecting your interests where we believe we have a duty to do so
Sometimes, we must process your information in order to comply with a statutory obligation.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
This may include your personal information.
If you complain about any of the content on our website, we shall investigate your complaint.
If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.
Free speech is a fundamental right, so we have to make a judgment as to whose right will be obstructed: yours, or that of the person who posted the content that offends you.
If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.
Payment information is never taken by us or transferred to us either through our website or otherwise. Our employees and contractors never have access to it.
If you send us information in connection with a job application, we may keep it for up to three years in case we decide to contact you at a later date.
When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.
We record your request and our reply in order to increase the efficiency of our business.
We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.
When we receive a complaint, we record all the information you have given to us.
We use that information to resolve your complaint.
If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.
We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.
Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.
Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use.
When you first visit our website, we ask you whether you wish us to use cookies. If you choose not to accept them, we shall not use them for your visit except to record that you have not consented to their use for any other purpose.
If you choose not to use cookies or you prevent their use through your browser settings, you will not be able to use all the functionality of our website.
We use cookies in the following ways:
• to track how you use our website;
• to record whether you have seen specific messages we display on our website;
• to record your answers to surveys and questionnaires on our site while you complete them;
• to record the conversation thread during a live chat with our support team
This data processing is based on art. 6 section 1.f GDPR for the protection of our legitimate interests, namely the optimisation of our offer.
Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.
Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use.
No such information is personally identifiable to you.
We may share your information with third parties (“Service Partners”) that perform services for us or on our behalf, including data analysis, email delivery, hosting services, customer service, and marketing assistance. Although we may use other third party providers from time to time, we use the following main Service Partners named below to process and store your data:
• Mailchimp (The Rocket Science Group, LLC), which we use to manage email marketing subscriber lists and send emails to our subscribers. Read their privacy policy.
• GoDaddy, which hosts our domain and acts as our email service provider. Read their privacy policy.
• Webflow which host this website and whose software (and associated add-ons) we use to manage the content of this website and collect form submissions via the site. Read their privacy policy.
We will not share your personal information with any other third-party unless we have your permission or the law requires us to.
Our website is hosted in the United States of America.
Information about our Service Partners appears in the preceding section (14). We may also use other outsourced services in countries outside the European Union from time to time in other aspects of our business.
Accordingly, data obtained within the UK or any other country may be processed outside the European Union.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see: European Commission: Adequacy of the protection of personal data in non-EU countries
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
It is important that any personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.
At any time, you may review or update personally identifiable information that we hold about you, by signing in to your account on our website.
To obtain a copy of any information that is not provided on our website you should contact us to make that request.
After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.
If you wish us to remove personally identifiable information from our website, you should contact us to make your request.
This may limit the service we can provide to you.
When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
If you no longer wish to receive correspondence, emails, or other communications from us, you may opt-out by:
• Noting your preferences at the time you submit your contact details with the Site;
• Contacting us using the contact information provided below;
• Opting out via the ‘Unsubscribe’ button on any marketing emails from us.
If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.
We do not sell products or provide services for purchase by children, nor do we market to children.
If you are under 18, you may only use our website with consent from a parent or guardian.
We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.
Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
If you are not happy with our privacy policy or if you have any complaint then you should tell us.
If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner's Office (ICO). This can be done at https://ico.org.uk/make-a-complaint/. We would, however, appreciate the opportunity to talk to you about your concern before you approach the ICO.
Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:
• to provide you with the services you have requested;
• to comply with other law, including for the period demanded by our tax authorities;
• to support a claim or defence in court.
Our privacy policy has been compiled so as to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you.
However, ultimately it is your choice as to whether you wish to use our website.
We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.
If you have any question regarding our privacy policy, please get in touch at: contact@lustrumpartners.com.
