PRIVACY POLICY
[version update 22 November 2018]

 

Introduction
LUCHFORD APM is a world-class creative communications partner for global luxury brands and businesses. We respect your privacy and are committed to protecting your personal data.

 

1. Important information and who we are
This privacy policy aims to give you information on how LUCHFORD APM collects and processes your personal data. This applies when you use our services or visit our website (regardless of where you visit it from). It outlines your privacy rights and how the law protects you.

LUCHFORD APM Limited (company number 04996602) (collectively referred to as “LUCHFORD APM”, “we“, “us” or “our” in this privacy policy) is a data controller in respect of certain personal data provided by (but not limited to) clients, journalists, influencers, job applicants and suppliers by email, personal contact or direct interaction, and is a data processor in respect of personal data in respect of clients, journalists, influencers and suppliers collected by other means.

It is important to us 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.

 

2. The data we collect about you
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).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes name, date of birth and passport details (for proof of identity or when making necessary travel arrangements)
  • Contact Data if an individual client includes address, email address and telephone number, and if a corporate client includes company name, job title, company email address and company telephone number
  • Personal Preference Data includes dietary requirements, personal preferences regarding airlines, hotels, media providers, etc., your interests, feedback and survey responses
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
  • 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 the Website.
  • Usage Data includes information about how you use the Website and our services such as the full uniform resource locations (URL) clickstream to, through and from the Website (including date and time), pages you viewed or searched for, page response times, download errors, length of visits of certain pages, page interaction information (such as scrolling, clicks and mouse-overs), and methods used to browse away from the page.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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; however, should a situation arise where we are required to, we will only do so with your explicit consent. Special Categories of Personal Data 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. We do not collect any information about criminal convictions and offences.

If you fail to provide personal data
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 the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

 

3. How is your personal data collected?
We use different methods to collect data from and about you, including through:

  • Direct interactions. You may give us your Identity, Contact, Personal Preference, and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • apply for our services;
    • request marketing to be sent to you;
    • apply for a job;
    • enter a competition, promotion or survey; or
    • provide us with feedback.
  • Automated technologies or interactions. As you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
  • Personal interactions. You may give us your Identity, Contact and Personal Preference Data by providing business cards, interacting with us via traditional or social media, or through personal relationships with a LUCHFORD APM representative.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
    • Technical Data from the following parties:
      • analytics providers;
      • advertising networks; and
      • search information providers.
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
  • Identity and Contact Data from media databases such as Gorkana.
  • Identity and Contact Data from data brokers or aggregators.
  • Identity and Contact Data from publicly available sources such as Companies House and a company’s website.

 

4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Purposes for which we will use your personal data
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.

 

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new client (a) Identity

(b) Contact

Performance of a contract with you
To process and deliver services 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 contact media including (but not limited to) editors, journalists and influencers which we believe are of interest and relevance to you (a) Identity

(b) Contact

(c) Personal Preference

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to provide services to clients)

To provide you with additional services such as booking a flight or hotel on your behalf or sending you birthday and Christmas cards (a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Personal Preference

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to provide services to clients)

To provide you with information on services that you have indicated are of interest to you, or which we reasonably believe are of interest to you (a) Identity

(b) Contact

(c) Personal Preference

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to provide services to clients)

To provide you with event invitations that you have indicated are of interest to you, or which we reasonably believe are of interest to you (a) Identity

(b) Contact

(c) Personal Preference

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to provide services to clients)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Personal Preference

(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 clients use our products/services)

To enable you to partake in a prize draw, competition or complete a survey (a) Identity

(b) Contact

(c) Personal Preference

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how clients use our products/services, to develop them and grow our business)

To administer and protect our business and the 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 to you and measure or understand the effectiveness of content (if required) (a) Identity

(b) Contact

(c) Usage

(d) Marketing and Communications

(e) Technical

Necessary for our legitimate interests (to study how clients use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve the Website, products/services, marketing, client relationships and experiences (a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of clients 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) Personal Preference

Necessary for our legitimate interests (to develop our products/services and grow our business)
To liaise with you during the job application process (a) Identity

(b) Contact

 

Necessary to confirm your identity and suitability for the role, and communicate with you

 

 

Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and communications.

We may use your Identity, Contact, Technical, Usage and Personal Preference Data to form a view on what we think you may want or need, or what may be of legitimate interest to you. This is how we decide which services and offers may be relevant for you. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and communications.

You may change your preferences to receive direct marketing communications from us by contacting us.

 

Third party marketing
We would only share your personal data with third parties for marketing purposes with your express opt-in consent.

 

Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out (or unsubscribe) 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 you purchasing services from us.

 

Website
With regards your use of the website at http://www.luchfordapm.com and its associated sub-domains (the “Website”), we will adhere to the same privacy policy processes including any personal data you may provide through the Website, for example, if you were to sign up to a newsletter, purchase any service or take part in a competition.

 

Third party links
The 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 the Website, we encourage you to read the privacy policy of every website you visit.

The Website is not intended for children and we do not knowingly collect data relating to children.

 

Cookies
Cookies help to distinguish you from other users of the Website, helping to provide you with a good experience when you browse the Website and also allows us to improve the Website.

Cookies may include the following:

  • Strictly necessary cookies. These are cookies that are required for the operation of the Website. If you block these cookies, the Website will not operate properly.
  • Analytical/performance cookies. These cookies allow us to recognise and count the number of visitors and to see how visitors navigate around the Website when they are using it. This helps us to improve the way the Website works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies. These cookies are used to recognise you when you return to the Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Targeting cookies. These cookies record your visit to the Website, the pages you have visited and the links you have followed. We will use this information to make the Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that external third-parties may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Website may become inaccessible or not function properly.

 

Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

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.

Please note that 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.

5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

  • External third-parties which include processors in the following categories:
    • Payments and liquidity providers
    • Analytics
    • Advertising
    • Customer Service
    • Hosting
    • Hospitality providers including, but not limited to, travel agencies, event organisers, hotels and airlines
  • Third-parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third-parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

6. International transfers
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

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:

  • 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.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

 

7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third-parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.  We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements. In some circumstances you can ask us to delete your data: see ‘Request Erasure’ below for further information. In some circumstances we may 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.

 

9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.

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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

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 exercise any of the rights set out above, please contact us.

No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Contacting us
We care about your privacy and understand how important your personal data is. We respect and value all the personal data we hold and only collect and use that data in a way that is consistent with our obligations and your rights under the law.

If you are currently in our database, it’s because we’ve been in communication with you previously, collected your details from a secure media database or former business interaction. You have the right to access, amend, update or delete any of your personal data.

If you would prefer not to receive communications from us, would like to talk to someone about the data we hold, or have any questions about this privacy policy, please contact us at the details below and we will be in touch.

LUCHFORD APM Limited
Kirkman House, 12-14 Whitfield Street, London, W1T 2RF, UK.
info@luchfordapm.com
+44 (0)20 7631 1000

 If we are unable to address your concerns, you are within your rights to contact the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).