LYBRA PRIVACY NOTICE
LYBRA is committed to protecting and respecting your privacy. Your privacy is very important to us, which is why we make sure you are always in control of what we do with your personal information.
The purpose of this notice is to tell you what information we collect from you, how and when it may be collected and what happens to it. For the purpose of this notice “we”, “our” and “us” refers to LYBRA (“the Association”)
The Association is a data controller and can be contacted using the contact details below. This means that we make decisions about how and why we use your personal data and, because of this, we are responsible for making sure it is used in accordance with applicable data protection laws.
This notice only applies to personal information processed by or on behalf of the Association.
We may collect information from you when you visit our website, use our services, contact us by telephone or email or receive a communication from us relating to our services. If you are a business customer, this notice applies to the information you provide to us about individual participants/contacts from within your business (for example directors), or information about you as a sole trader or partnership.
You can contact us by emailing:
Eric G.F. BLAIR
Secretary General – SG@lybra.org
If you have a specific question about this notice or how we use your personal information, you should contact us via the postal or email address set out above; please mark your communication as ‘Data Protection Enquiry’.
In this notice the following words will have the following meanings:
Data Protection Laws means any applicable law relating to the processing, privacy, and use of Personal Data, including (a) Laws 1353 and 1354 (Principality of Monaco) 04/12/2018.; and/or (ii) the General Data Protection Regulation (EU) 2016/679 (GDPR), Data Protection Act 2018 and/or any corresponding or equivalent national laws or regulations (b) in member states of the European Union, the GDPR and the ePrivacy Directive, and all relevant member state laws or regulations giving effect to or corresponding with any of them; and (c) any judicial or administrative interpretation of any of the above, any guidance, guidelines, codes of practice, approved codes of conduct or approved certification mechanisms issued by any relevant supervisory authority;
Personal Data means any information relating to an identified or identifiable natural person (“Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person and where referred to in this notice includes special categories of personal data.
2. INFORMATION WE COLLECT FROM YOU
2.1. We will collect and process the following Personal Data about you:
2.1.1. Information you give us. This is information about you that you give us by contacting us via our website at www.coote.com (“our site”) or by corresponding with us by telephone, e-mail or otherwise. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information
2.1.2. Information we collect about you. With regard to each of your visits to our site we will automatically collect the following information:
126.96.36.199 personal and contact details you give us when subscribing to receive marketing information from us (for example name, role and email address);
188.8.131.52 technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform,;
184.108.40.206 information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for’ page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page.
220.127.116.11 information from social media activity (such as likes, shares and tweet) when you interact with us on social media;
18.104.22.168 information you provide if you report a problem with our website or service.
3. INFORMATION WE RECEIVE FROM OTHER SOURCES
We also obtain information from other sources of data including information about you from 3rd party organisations. We will only accept and use information about you from reputable organisations who have either obtained your permission to share your information with us or who have collated information about you from publicly available sources.
A cookie is text file that is stored on your computer or mobile device by a website’s server. Each cookie contains anonymised information about how you use our website and applications, which allows us to improve your experience of using our products and services.
5. USES MADE OF THIS INFORMATION
5.1. We will only use your Personal Data to the extent that the law allows us to do so. Under the Data Protection Laws we will rely on the following legal bases for processing your Personal Data:
5.1.1. where you have given us your consent;
5.1.2. where it is necessary to perform a contract we have entered into or are about to enter into with you;
5.1.3. where it is necessary for the purposes of our legitimate interests (or those of a third party) and your interests or fundamental rights and freedoms do not override those interests.
5.2. Information you give to us. We will use this information:
5.2.1. to process an enquiry received from you, or responding to an expression of interest in our services;
5.2.2. to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
5.2.3. we will provide your information to third party suppliers in order to facilitate the provision of our services to you, for example freelancers, furniture providers or photographers. Engagement and use of such suppliers will vary, depending on the scope of work that we undertake for you. We will ensure that you are provided with a list of appointed suppliers in advance of our sharing your Personal Data with them. We will have agreements in place with such service providers which will restrict how they are able to process your information and impose appropriate security standards on them. In carrying out their services these service providers may become Data Controllers. They will have their own privacy notices which you should read, and they have their own responsibilities to comply with applicable data protection laws.
5.2.4. to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
5.2.5. to provide your information to our marketing department who may contact you by post or email to request feedback and comments on our services or to provide information to you which may be of interest to you;
5.2.6. to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, you will be able to withdraw your consent by contacting us via the contact details set out above.
5.2.7. We will use SMS and/or Whatsapp to correspond with you during the term of the services provided to you, as well as via your contact number(s) and email address(es).
5.2.8. to notify you about changes to our services;
5.2.9. to ensure that content from our site is presented in the most effective manner for you and for your computer;
5.3. Information we collect about you. We may use this information:
5.3.1. to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
5.3.2. to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
5.3.3. to allow you to participate in interactive features of our service, when you choose to do so;
5.3.4. as part of our efforts to keep our site safe and secure;
5.3.5 to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
5.3.6. to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
5.4. Information we receive from other sources. We will use this information to combine with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
6. DISCLOSURE OF YOUR INFORMATION
6.1. We may use third party search providers to support our provision of the service. This could include cloud storage providers, or other, less direct business functions, including (without limitation) IT support, hosting our data on cloud platforms, legal, accounting, audit, consulting and other professional service providers, and providers of other services related to our business. Portions of our services may be provided by organisations with which we have a contractual relationship with, including subcontractors, and, accordingly, your personal information may be disclosed to them. We only provide these organisations with the information that they need to be able to perform their services.
6.2. You agree that we have the right to share your personal information with selected third parties including:
6.2.1. business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
6.2.2. advertisers and advertising networks that require the data to select and serve relevant adverts to you and others;
6.2.3. analytics and search engine providers that assist us in the improvement and optimisation of our site; and
6.3. We will disclose your personal information to third parties:
6.3.1. in the event that we sell or buy any business or assets, in which case we will disclose your Personal Data to the prospective seller or buyer of such business or assets;
6.3.2. if the Company or substantially all of its assets are acquired by a third party, in which case Personal Data held by it about its clients will be one of the transferred assets; or
6.3.3. if we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or in order to enforce or apply our standard terms and conditions of business and other agreements; or to protect the rights, property, or safety of the Company, our clients, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
7. SENSITIVE INFORMATION
We may collect other sensitive information if it is provided to us by you or on your behalf voluntarily. By giving us this information, you agree that we may use such information as set out in this notice.
8. WHERE WE STORE YOUR PERSONAL DATA
8.1. All information you provide to us is stored on cloud based solutions and storage platforms.
8.2. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
9. INTERNATIONAL TRANSFER
9.1 If we transfer your Personal Data outside the European Union, we will only make that transfer if:
9.1.1. that country ensures an adequate level of protection for your Personal Data;
9.1.2. the recipient or recipient country is subject to an approved certification mechanism or code of conduct with binding and enforceable commitments which amount to appropriate safeguards for your Personal Data – this includes for example, the EU-US Privacy Shield which enables the secure transfer of personal data to the United States;
9.1.3. we have put in place appropriate safeguards to protect your Personal Data, such as a contract with the person or entity receiving your Personal Data which incorporates specific provisions as directed by the European Commission;
9.1.4. the transfer is permitted by applicable laws; or
9.1.5. you explicitly consent to the transfer.
9.2 We have not set out the specific circumstances when each of these protection measures are used. You can contact us at the contact details above for the details as to how we protect specific transfer of your Personal Data.
10. RETENTION OF YOUR PERSONAL DATA
10.1. We will only retain your Personal Data for as long as necessary to fulfil the purposes for which we collected your Personal Data.
10.2. 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 that 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 requirements.
11. CONTROL OF AND ACCESS TO YOUR INFORMATION
You may withdraw your consent to receiving marketing at any time by emailing SG@lybra.org
We also offer the following controls:
11.1.1. you may request access to or copies of the personal information that we hold about you. If you would like to exercise this right, please contact us at SG@lybra.org
11.1.2. if you believe that any information we have about you is incorrect or incomplete, please contact us at SG@lybra.org as soon as possible. We will take steps to seek to correct or update any information if we are satisfied that the information we hold is inaccurate. You may request that we restrict our processing;
11.1.3. you may request that your personal information be deleted where it is no longer necessary for the purposes for which it is being processed and provided there is no lawful basis for which we may continue to process such information;
11.1.4. if we are processing your personal information to meet our legitimate interests (as set out above), you may object to the processing of your personal information by us. If we are unable to demonstrate our legitimate grounds for that processing, we will no longer process your personal information for those purposes;
11.1.5. if you have objected to our processing as out above;
11.1.6. you may withdraw any consent given to processing (this will not affect the lawfulness of processing based on consent before its withdrawal); or
11.1.7. if we are processing your personal information automatically for the purposes of performing our contract with you, you may have the right to request that the personal information we hold about you be transferred to a third party data controller.
You may also request that we restrict the processing of your data to that to which you have consented or for the establishment, exercise or defence of legal claims or the protection of the rights of another person, whilst we verify your data as set out in point 11.1.2 above; pending verification of our legitimate grounds as set out in point 11.1.4 above; or if the processing is unlawful or no longer necessary, but you wish us to retain your data for the purposes of establishing, exercising or defending legal claims.
Please contact us if you would like to exercise any of these rights or if you have any concern about how your personal information is processed at SG@lybra.org and we will try to resolve your concerns. However, if you consider that we are in breach of our obligations under data protection laws, you may lodge a complaint with the Information Commissioner’s Office (https://ico.org.uk/global/contact-us/). You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the GDPR.
12. CHANGES TO OUR PRIVACY NOTICE
Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.