PRIVACY INFORMATION NOTICE
Last modified in April 2020.
This Data Privacy Notice describes the collection and further processing of personal data by (Getlumiere, Inc.). In the event that the activities covered by this notice are governed by other data protection policies, are evident from the circumstances, or are governed by applicable laws outside of the European Union and the European Economic Area, then such applicable law and resulting policies shall control. The term personal data shall include all information relating to an identified or identifiable person.
This Data Privacy Notice describes in Section I processing of personal data by Getlumiere, Inc. in general. Section II contains specific provisions for specific applications (e.g. online-shop, newsletter and banner advertisement) and Section III contains specific provisions for customer programs.
If you provide Getlumiere, Inc. with personal data of other persons, for example, data about the receiver of a gift, please provide their personal data to Getlumiere, Inc. only if you are allowed to do so pursuant to applicable data protection laws and only if the other person would agree to you providing its personal data to Getlumiere, Inc. for the purposes the data are collected and the processing of its personal data according to our data privacy notice.
I. GENERAL PROVISIONS
1. CONTROLLER, DATA PROTECTION OFFICER
HOW TO CONTACT Getlumiere, Inc.
If you want to exercise any of your rights regarding newsletter subscriptions, data access or data deletion, please do not hesitate to contact our customer care, who will be happy to answer any questions you may have.
2. PROCESSING OF PERSONAL DATA
Getlumiere, Inc. collects and processes personal data of:
- users of Getlumiere, Inc. registered WEBSITES;
- users registered with a Getlumiere, Inc. WEBSITE (e.g. if he or she creates a user account);
- individuals purchasing and receiving/benefiting from products and services of Getlumiere, Inc.;
- potential or actual parties interested in products and services of Getlumiere, Inc.;
- recipients of Getlumiere, Inc. newsletters;
- participants in research campaigns and opinion surveys conducted by Getlumiere, Inc.;
- participants in courses, seminars and other training organized by Getlumiere, Inc.;
- registered participants of customer loyalty programs or individuals purchasing or using customer loyalty programs of Getlumiere, Inc. (CUSTOMER PROGRAM) (together CUSTOMERS).
The personal data of CUSTOMERS is generally collected directly by Getlumiere, Inc. during the course of using the WEBSITE, as well as through direct communication such as email, telephone, events or in any other way. Personal data can also be collected indirectly, such as through third-party processors, (e.g., Getlumiere, Inc.’s PARTNERS (as defined further below, including customer services vendors and order fulfillment services). Getlumiere, Inc. also collects data when the CUSTOMER making the purchase does not correspond with the person benefiting from the purchase or if the purchase is shipped to a different person (e.g. as a gift), based on the recommendation of a third party (e.g. recommendation by family or friends of the CUSTOMER) or through further acquisition of supplementary information from third-party data sources (e.g. social media).
In particular, the following categories of personal data are processed by Getlumiere, Inc.:
- Personal data and contact information including but not limited to first and last name, address, residence, telephone number, email address, age, date of birth, gender, marital status, relatives, contact in case of emergency, pictures;
- Data pertaining to orders and purchases including but not limited to payment information, credit card details and other payment details (in accordance with other laws and regulations), billing and shipping address, products and services ordered and purchased, information and queries and complaints relating to products and services, or respective contracts entered into such as returns policies, after-sales services, customer care and services, recessions and disputes;
- Data in connection with product and services marketing including but not limited to information relating to newsletters and other communication channels, opt-ins and opt-outs, invitations to and participation at events and special activities (as far as they are not part of a customer loyalty program), personal preferences and interests, and customer segmentation information;
- Data concerning the use of the WEBSITE including but not limited to the IP address and other user identification (e.g. user name of social media, MAC address of smartphones or computers, cookies), date and time of WEBSITE visits, visited sites and contents, and referring websites;
- Data in connection with communication including but not limited to preferred means of communication, correspondence and communication with Getlumiere, Inc. (including records of the communication);
- Data which was collected in connection with a customer program including but not limited to membership numbers, access codes (including passwords), preferred language, number of a gift certificate, date and duration of the membership, payment information of the CUSTOMER or a potential third party, information concerning the recipient of a gift, number of visits of the WEBSITE, purchase history, products acquired (all WEBSITE accounts, activities, and events for which a CUSTOMER must register with his or her personal data and thus enter into a contract with Getlumiere, Inc. shall be deemed a customer program for the purposes of this policy, other than traditional customer loyalty programs); together CUSTOMER DATA.
In addition, Getlumiere, Inc. collects:
- Data of users of the WEBSITE, who do not register with Getlumiere, Inc. (VISITOR) but may constitute personal data for example with social media (VISITOR DATA), the provisions of this notice regarding data collected from a CUSTOMER in connection with the use of the WEBSITE shall apply accordingly even though the identification of a VISITOR usually is not possible for Getlumiere, Inc.;
- Information pertaining to employees and other individuals acting on the part of vendors, dealers, suppliers and further business partners of Getlumiere, Inc. (hereinafter natural persons shall be referred to as PARTNERS, their data as PARTNER DATA) including but not limited to contact details, information regarding their function, information relating to the previous contact with these individuals, data regarding marketing activities (e.g. receipt of newsletters), information regarding business transactions, requests, offers, tenders, conditions and contracts, information related to professional or other interests of the individuals.
Within the framework of their business relationship, CUSTOMERS will be required to provide CUSTOMER DATA necessary for the establishment and execution of the contractual relationship and the fulfillment of the associated contractual obligations or if required by law. Without these data, Getlumiere, Inc. will generally not be able to conclude or execute the contract with the respective CUSTOMER. This also applies analogously to the PARTNER DATA as far as business relations with the wholesalers, dealers, retailers, suppliers and business partners of Getlumiere, Inc. are concerned; contracts in principle cannot be concluded and processed without information on their employees and other contacts. As any access to the WEBSITE is logged, connection data (such as the IP address) will always be logged; this is done automatically during the use and cannot be deactivated for individual VISITORS, CUSTOMERS or PARTNERS.
3. PURPOSE OF PROCESSING AND LEGAL GROUNDS
3.1. PURPOSE of the processing In accordance with applicable law, Getlumiere, Inc. may process CUSTOMER DATA for all lawful PURPOSES including but not limited to the following:
- In connection with services offered, conclusions of contracts (for example purchases), executions of contracts (for example purchase contracts and contracts regarding the participation at customer programs and events), maintenance and development of customer relations, communication, customer service, and support, promotions, advertisement and marketing (including newsletters and mailing of promotional materials);
- Management of the users of the WEBSITE and other activities in which CUSTOMERS participate, operation and enhancement of the WEBSITE (including the provision of functions which require identifiers or other personal data) and additional IT systems and identity verification;
- protection of CUSTOMERS, employees and other individuals and protection of data, secrets, and assets of and entrusted to Getlumiere, Inc., and the protection of the safety of systems and premises of Getlumiere, Inc.;
- Compliance with legal and regulatory requirements, including the internal rules of Getlumiere, Inc., enforcement, and exploitation of legal rights and claims, defense against legal claims, litigation, complaints, combating abusive conduct, engaging in legal investigations and proceedings and responding to inquiries of public authorities;
- Sale or acquisitions of business divisions, companies or parts of companies and other corporate transactions and the transfer of CUSTOMER DATA associated therewith; and
- For other lawful purposes where such processing was evident from the circumstances or indicated at the time of the collection (together the PURPOSE OF CUSTOMER DATA PROCESSING).
3.2. LEGAL GROUNDS of processing
Getlumiere, Inc. uses CUSTOMER DATA for the PURPOSE OF CUSTOMER DATA PROCESSING based on the following LEGAL GROUNDS:
- performance of contracts;
- compliance with legal obligations of Getlumiere, Inc.;
- consent of the CUSTOMER (only insofar as the processing is based on a specific query and can be withdrawn at any time, for example, the receipt of newsletters for which the CUSTOMER has registered for);
- legitimate interests of Getlumiere, Inc., including but not limited to
- purchase and shipment of products and services, also in connection with individuals who are not direct contractual partners (such as e.g. individuals receiving a gift);
- advertising and marketing activities;
- efficient and effective customer support, maintenance of contact and other communication with CUSTOMERS outside of the processing of contracts;
- understanding CUSTOMER behavior, activities, concerns, needs, and market studies;
- efficient and effective improvement of existing products and services and development of new products and services;
- efficient and effective protection of CUSTOMERS, employees, and other individuals, as well as protection of data, secrets, and assets, are entrusted to Getlumiere, Inc., protection and safety of systems and premises of Getlumiere, Inc.;
- maintenance and secure, efficient and effective organization of business operations including a secure, efficient and effective operation and successful further development of the WEBSITES and other IT systems;
- reasonable corporate governance and development;
- successful sale and acquisition of business units, companies or parts of companies and other corporate transactions;
- compliance with legal and regulatory requirements and internal rules of Getlumiere, Inc.;
- concerns regarding the prevention of fraud, offenses, and crimes as well as investigation in connection with such offenses and other improper conduct, handling of claims and actions against Getlumiere, Inc., cooperation in legal proceedings and with public authorities as well as the prosecution, exercise of and defense against legal actions.
In accordance with applicable data protection laws, Getlumiere, Inc. may process VISITOR DATA for the purpose of maintaining and developing the WEBSITE (including the provision of functions which require identifiers or other personal data), for statistical analysis regarding the use of the WEBSITE as well as for combating abusive conduct, for purposes of legal investigations or proceedings and for the response to inquiries of public authorities. The VISITOR DATA shall be processed in accordance with the principles set out for CUSTOMER DATA above.
In accordance with applicable data protection laws, Getlumiere, Inc. may process PARTNER DATA for the purpose of entering into and performance of contracts and other business relationships with PARTNERS, promotions, advertisement, and marketing, communication, invitations to events and participation in promotions for PARTNERS, organization of joint activities, compliance with legal and regulatory requirements and internal rules of Getlumiere, Inc., enforcement and exploitation of legal rights and claims, defense against legal claims, litigation, complaints, combating abusive conduct, engaging in legal investigations and proceedings and responding to inquiries of public authorities, for the sale or acquisition of business units, companies or parts of companies and other corporate transaction and related transfers of PARTNER DATA. The PARTNER DATA shall be processed in accordance with the principles set out for CUSTOMER DATA above.
All the purposes of processing shall be applicable for the whole Getlumiere, Inc. Group, i.e. not only for the company which initially collected the personal data. Personal data of CUSTOMERS, VISITORS and PARTNERS are collected for the purpose of all Getlumiere, Inc. companies subject to this data privacy notice, any other policies developed by Getlumiere, Inc. and pursuant to applicable data protection laws.
4. TRANSFER AND DISCLOSURE OF DATA
In accordance with applicable data protection laws, Getlumiere, Inc. may transfer CUSTOMER DATA, VISITOR DATA and PARTNER DATA to the following categories of third parties who process PERSONAL DATA in accordance with the PURPOSE OF DATA PROCESSING on behalf of Getlumiere, Inc. or for their own purposes:
- service providers (within Getlumiere, Inc. as well as external), including processors;
- dealers, vendors, suppliers and other business partners;
- customers of Getlumiere, Inc.;
- local, national and foreign authorities;
- the public including visitors of WEBSITES and social media of Getlumiere, Inc.;
- industry organizations, associations, organizations, and other committees;
- acquirers or parties interested in acquiring business units, companies or other parts of Getlumiere, Inc.;
- other parties in potential or actual legal proceedings;
- other Group companies of Getlumiere, Inc. (together THIRD PARTIES).
Getlumiere, Inc. may disclose CUSTOMER DATA, VISITOR DATA, and PARTNER DATA within Getlumiere, Inc. as well as to THIRD PARTIES and in every country worldwide, including namely all countries in which Getlumiere, Inc. is represented by Group companies, affiliates or other offices and representatives (see ANNEX 2, as updated from time to time) as well as to countries in which service providers of Getlumiere, Inc. process their data (see ANNEX 2, as updated from time to time). If data is disclosed to countries that do not guarantee adequate protection, Getlumiere, Inc. will ensure adequate protection of data disclosed of CUSTOMERS, VISITORS or PARTNERS by putting adequate contractual guarantees in place, (e.g., on the basis of EU standard clauses), binding corporate rules, on the basis of the EU-U.S. and the Swiss-U.S. Privacy Shield Framework for transfers to THIRD PARTIES based in the U.S., or transferring data pursuant to consent, conclusion or performance of a contract, or in connection with the determination, exercise or enforcement of legal claims, or pursuant to overriding public interests, or in order to protect the integrity of these individuals. The CUSTOMER, VISITOR or PARTNER can obtain a copy of the contractual guarantees from or will be advised where to obtain such copies by the contact points named above (see para. 1 above). Getlumiere, Inc. reserves the right to redact such copies for applicable legal or secrecy reasons.
5. RETENTION OF DATA
In general, Getlumiere, Inc. retains personal data for no longer than it is necessary for the purposes for which the personal data are processed. Notwithstanding the general principle, Getlumiere, Inc. may process personal data for longer periods subject to the following rules and obligations: Getlumiere, Inc. retains personal data as long as Getlumiere, Inc. (i) is obligated to do so (by way of contract, law or other provisions) or (ii) has an overriding interest (e.g. an interest for reasons of proof in case of claims, documentation of compliance with certain legal or other requirements, and interest in non-personalized analysis). Deviating rules are reserved with respect to anonymization or pseudonymization of personal data subject to applicable law.
As a rule for contract-related CUSTOMER DATA and PARTNER DATA (including business records and communication) Getlumiere, Inc. retains personal data as long as the contractual relationship is ongoing and for ten years after the termination of the contractual relationship unless (i) a shorter or longer statutory storage obligation is applicable on a case-by-case basis, (ii) the retention is required for reasons of proof or another valid reason based on applicable law, or (iii) the deletion of the data is required earlier (because e.g. the data is no longer required or Getlumiere, Inc. is required to delete the respective data).
As a rule for operational data containing CUSTOMER DATA, VISITOR DATA or PARTNER DATA (e.g. protocols, logs), Getlumiere, Inc. retains personal data for a period of 3 - 12 months.
6. COOKIES, GOOGLE ANALYTICS, AND SOCIAL PLUG-INS
In accordance with applicable law, Getlumiere, Inc. may install coding in newsletters and other marketing emails which allow it to determine if the recipient has opened an email or downloaded pictures contained in the email. However, the recipient may block this application in his/her email application. In any case, he/she consents to the application of this technology by way of receiving newsletters or other marketing-related emails.
In the event that Getlumiere, Inc. places advertisements of third parties on the WEBSITE (e.g. banners) or places an own ad on the website of a third party, cookies from companies specializing in the use of such advertisement may be employed. Getlumiere, Inc. will not disclose personal data to such companies, i.e. they shall only place a permanent cookie with users of the WEBSITE in order to recognize users and do so in the sole interest of Getlumiere, Inc. This allows Getlumiere, Inc. to place aimed advertisements for these individuals on external third party websites (e.g. in connection with products for which these individuals showed an interest in the online-shop). Getlumiere, Inc. will not disclose personal data to the operators of external websites.
Getlumiere, Inc. may use Google Analytics or similar services on its WEBSITE. These applications are third-party services that allow Getlumiere, Inc. to measure and analyze the use of its WEBSITE. The provider of these services may be located in any country worldwide (in the case of Google Analytics which is operated by Google Inc. it is the U.S., www.google.com). The service provider uses permanent cookies for these applications. Getlumiere, Inc. will not disclose any personal data to the service provider (who will also not save any IP addresses). The service provider may, however, monitor the use of the WEBSITE by the user and combine this data with data from other websites monitored by the same service provider which the user has visited and the service provider may use these findings for its own benefits (e.g. control of advertisement). The service provider knows the identity of the user who has registered with the service provider. In this case, the processing of personal data will be the service provider's responsibility and data shall be processed pursuant to data protection and privacy laws and according to the data protection policies of the service provider (for Google see policies.google.com/privacy). The service provider will provide data on the use of the WEBSITE to Getlumiere, Inc.
In addition, Getlumiere, Inc. may use plug-ins from social media networks such as Facebook, Twitter, Youtube, Google+, Pinterest or Instagram on its WEBSITE. In the default setting of the WEBSITE, plug-ins are deactivated; the user can thus choose when to activate them. Should the user do so, the social media providers are able to establish a direct connection to the user during his or her visit on the WEBSITE, which allows the provider to be aware of the user's visit and may analyze the respective information. The subsequent processing of the personal data will be conducted in the responsibility of the social media provider pursuant to data protection and privacy laws and according to its data protection policies published on its website (such as www.facebook.com/; www.twitter.com/; www.youtube.com/; www.google.com/; www.pinterest.com/; www.instagram.com/; www.snapchat.com/).
You can find more information about Cookies used by Getlumiere, Inc. and how to manage your cookie settings on our WEBSITE.
7. RIGHTS OF THE CUSTOMER, VISITORS, AND PARTNERS
Any affected individual, including any CUSTOMER, VISITOR, and PARTNER, may request information from Getlumiere, Inc. as to whether data concerning them is being processed. In addition, they have the right to request the correction, destruction or restriction of personal data regarding them as well as to object to the processing of personal data. Should the processing of personal data be based on consent, the affected individual may withdraw consent at any time. In countries of the EU and EEA, the affected individual may, in certain cases, have the right to obtain data generated during the use of online services in a structured, common and machine-readable format which allows for further use and transfer. Requests in this respect shall be submitted to the contact point (see para. 1 above). Getlumiere, Inc. reserves the right to restrict the rights of the affected individual in accordance with applicable law and e.g. not to disclose comprehensive information or not to delete data.
In the event that Getlumiere, Inc. makes an automated decision with respect to a certain individual which may have a legal effect for the affected individual or seriously affect him or her in a similar way, the affected individual shall have, in accordance with applicable law, the right to communicate with a controller of Getlumiere, Inc. and to request a reconsideration of the decision or to request the prior evaluation by the controller. In this case, the affected individual may no longer be able to use certain automated services. The individual will be informed thereof subsequently or separately in advance.
Any affected individual may also raise a complaint with the competent data protection authority, which in the case of a Getlumiere, Inc. controller in the United Kingdom is the British Information Commissioner's Office (ICO): (https://ico.org.uk/).
8. CHANGES TO THE DATA PRIVACY NOTICE
Getlumiere, Inc. reserves the right to amend this Data Privacy Notice at any time and without prior notice or announcement. The latest version posted on the Getlumiere, Inc. WEBSITE shall be applicable. Should the Data Privacy Notice form part of an agreement with CUSTOMERS and PARTNERS, Getlumiere, Inc. may inform them of an update or amendments by email or in another appropriate manner. The amendments shall be deemed to have been accepted unless an objection is raised within 30 days of notification. In case of objection, Getlumiere, Inc. shall be free to terminate the agreement exceptionally and with immediate effect.
II. SPECIFIC PROVISIONS
The following provisions shall supplement the general provisions in Section I for certain activities of Getlumiere, Inc. In the event there is any inconsistency, the following provisions shall control.
The creditworthiness of CUSTOMERS may be evaluated automatically in online-shops in order to offer the purchase on account based on this decision. In this case, the credit rating is evaluated on the basis of information from an external credit rating agency, which will provide Getlumiere, Inc. with a credit score of the respective CUSTOMER. The agency will calculate the score based on a secret formula based on data on the payment history of the CUSTOMER, its debt and insolvency history and possible limitations of its legal capacity. Should the score be below a certain threshold no payment by invoice will be offered. In this event, the CUSTOMER may contact the contact person shown on the imprint of the respective website of the online-shop if he/she is not ready to accept the decision.
Online shops of Getlumiere, Inc. may automatically decide whether to enter into purchase agreements. However, Getlumiere, Inc. does not deem this an automated individual decision (according to article 22 of the GDPR). In the event the CUSTOMER does not wish such an automated entering into an agreement, it has the option to purchase products and services from Getlumiere, Inc. physical stores.
2. PARTNERS, INCLUDING SUPPLIERS, VENDORS, DEALERS, CUSTOMER SERVICES ETC.
As previously indicated, CUSTOMER DATA, PARTNER DATA, and VISITOR DATA are generally collected directly by Getlumiere, Inc. but also indirectly, (e.g. when Getlumiere, Inc. requests THIRD PARTIES to act as processors, such as Getlumiere, Inc.’s PARTNERS). In these cases, Getlumiere, Inc.’s PARTNERS process personal data on behalf and under the instruction of Getlumiere, Inc. and are bound by specific processor agreements covering the terms and conditions of their duties in a manner to ensure the protection of the rights of our CUSTOMERS, PARTNERS and VISITORS and the processing and security of their personal data in accordance with applicable data protection laws.
3. NEWSLETTER AND BANNER ADVERTISEMENT
Getlumiere, Inc. may send newsletters or other commercial communications in connection with its products and services to CUSTOMERS and PARTNERS. In accordance with applicable law, Getlumiere, Inc. reserves the right to do so without prior consent of existing customers and business partners. However, the respective customers and business partners may object to a further mailing of newsletters or other commercial communications at any time through their account on the respective WEBSITE or through the link indicated in every mailing. However, the termination of one newsletter may not entail the termination of other newsletters. Getlumiere, Inc. reserves the right to place personalized advertisements during WEBSITE visits. Such banner advertisements displayed to the CUSTOMER contain products offered on the WEBSITE which have previously been looked at by the CUSTOMER. The advertisement is generated by Getlumiere, Inc. by the means of cookies (see Section I para. 6 above).
4. SWEEPSTAKES and other PROMOTIONAL ACTIVITIES
The following provisions shall be applicable for the processing of data by Getlumiere, Inc. in connection with customer SWEEPSTAKES and other PROMOTIONAL ACTIVITIES.
The data in connection with the SWEEPSTAKE and other promotional activities are processed by the controller of the respective local Getlumiere, Inc. company which sponsors, promotes and organizes the sweepstake. Other companies and affiliates of Getlumiere, Inc. may, however, use the collected personal data for their purposes according to Section I para. 3 above.
With respect to SWEEPSTAKE and other PROMOTIONAL ACTIVITIES, Getlumiere, Inc. processes the personal data of participants according to Section I para. 2 above. for the purposes listed under that respective provision, and in particular also for the following purposes in accordance with applicable laws:
- carrying out the competition;
- contacting winners;
- publication of the contact details of the winners
- promoting winners on social media, and
- other promotional and marketing activities.
Further information regarding the SWEEPSTAKE and OTHER PROMOTIONAL ACTIVITIES can be found in the specific terms and conditions applicable to each SWEEPSTAKE and PROMOTIONAL ACTIVITY, as published and organized from time to time.
III. SPECIFIC PRIVACY NOTICE FOR CUSTOMER PROGRAMS
The provisions in this Section III shall specify the general provisions in Section I regarding customer programs of Getlumiere, Inc.
1. P&PPP CLUB
The following provisions shall be applicable for the processing of data by Getlumiere, Inc. in connection with the customer loyalty program P&PPP Club:
a. Responsible for the Personal Data (Controller)
The PERSONAL DATA in connection with the membership of Getlumiere, Inc. Club is processed by the controller of the respective local Getlumiere, Inc. company which issues the membership according to the sign-up form. Other companies and affiliates of Getlumiere, Inc. may, however, use the collected personal data for their purposes according to Section I para. 3 above.
b. Processing of Personal Data and Source
Getlumiere, Inc. collects and retains the personal obligatory data provided on the P&PPP Club sign-up form (including but not limited to: title, name, and address, and e-mail address) plus any personal data provided voluntarily by P&PPP Club Members on the member page: date of birth as well as styles/interests (e.g. in Jewelry and Accessories, Home and Style, Wedding, Figures and Collectables and/or Watches; Classic style) (“Form Data”). Getlumiere, Inc. also saves data on Members’ purchase history in the form of items purchased (product designation, price, discount), place and time of purchase and membership number. The purchase history is recorded if the P&PPP Club membership number is communicated at the checkout for purchases in stores participating in the P&PPP Club program. In the online store Members’ purchase history is recorded if the membership number is quoted when making a purchase or the Member makes a purchase when logged into an online account associated with a P&PPP Club membership.
Getlumiere, Inc. also collects and saves all vouchers sent to the P&PPP Club Member and, as the case may be, further data about the P&PPP Club Member's use of the Getlumiere, Inc. Group's online offerings and mailings (e.g., newsletter open rate, click rate, visited online web pages, social media interaction). Where Getlumiere, Inc. believes that two different P&PPP Club Memberships belong to the same individual, or where a valid request is received, Getlumiere, Inc. may merge them.
c. Purpose of Processing
As far as P&PPP Club is concerned, Getlumiere, Inc. namely collects and processes the personal data of Members of the customer loyalty program according to Section I para. 3 above and as specified below for the PURPOSES listed under that respective provision, and in particular also for the following PURPOSES:
- administration of P&PPP Club memberships;
- operation of the P&PPP Club, namely personalized offers, advice and communications regarding products and services of Getlumiere, Inc., providing of advantages and awarding special conditions (e.g. vouchers), invitations to special events and promotions reserved for members, participating in surveys, requiring feedback and act in social media.
The personal data collected is used by Getlumiere, Inc. to administer and manage the membership (including also for accounting purposes), to provide the Member with the benefits and other services that come with the Membership (the legal basis for this is the Membership).
On presentation of the P&PPP Club membership number, e-mail address or the Member’s name and date of birth (or another unique authentication attribute), the relevant sales employee have access to the relevant Member’s saved purchase history data and wish list.
Getlumiere, Inc. may also use PERSONAL DATA to invite selected Members to special events and promotions, such as the presentation of new products or discount promotions. In addition, Getlumiere, Inc. also uses PERSONAL DATA to send Members birthday congratulations.
Getlumiere, Inc. also uses the data collected in the purchase history to grant Members membership benefits in the form of Discount or Loyalty Gift vouchers. Based on the data saved in the purchase history, Getlumiere, Inc. evaluates what type of voucher the Member is granted.
If a Member has given Getlumiere, Inc. his or her consent, Getlumiere, Inc. may send the Member further information about Getlumiere, Inc., product information, services and exclusive offers by e-mail or in any other way chosen by Getlumiere, Inc. Based on the Form Data and the purchase history reported by participating stores, interaction variables (such as click rates, time of interaction or social media interaction), style/interests selected as well as other information voluntarily disclosed to Getlumiere, Inc. by the P&PPP Club Member, Getlumiere, Inc. may personalize the information sent to the Member so that the Member particularly receives, where possible, information which Getlumiere, Inc. seems interesting for the Member. For this purpose, Getlumiere, Inc. analyses the Form Data collected at the start of Membership and, in particular, takes account of the saved information relating to age, sex, interests and preferences, interaction variables as well as the vouchers received, and other information that can be gleaned from the purchase history or has been given to Getlumiere, Inc. by the Member voluntarily at any later time.
d. Disclosure of Personal Data
In the course of processing personal data in connection with P&PPP Club, Getlumiere, Inc. may namely disclose PERSONAL DATA to the following categories of recipients:
- PARTNERS, including business, marketing, and promotion partners (including social media partners) and all participating retail shops or other authorized specialists dealers, irrespective of whether the company is run by Getlumiere, Inc. or another sales or cooperation partner; whereas these stores may be located within any country worldwide and they may use data received from Getlumiere, Inc. only for the purpose of operating P&PPP Club, including personalized offers to and communication with Members on behalf of Getlumiere, Inc.;
- to a Getlumiere, Inc. company to whom the processing of data (operation of the database) regarding P&PPP Club has been outsourced in technical respect (processors).
Each recipient may be located in a country without an adequate level of data protection. If that is the case, Getlumiere, Inc. will ensure an adequate level of protection according to Section I para. 4 above.
e. Rights of Data Subjects
P&PPP Club Members are entitled at any time to ask Getlumiere, Inc.Getlumiere, Inc. for information relating to their saved personal data, and other information as provided for by applicable data protection law. Further information about the RIGHTS of P&PPP Club Members is provided in Section I para. 7 above.
f. Data Retention
Personal Data will be held and used for the duration of the Membership; thereafter, it will be retained as long as necessary for the aforementioned purposes, but not for more than five years, unless required for legal reasons. The purchase history is recorded for five years.