Privacy Policy and Cookie Statement – livaxl.co.uk

This is the Privacy Policy and Cookie statement of LivaXL and any of its affiliate entities part of the LivaXL Group (hereafter: “LivaXL”). In this statement we explain in short how LivaXL deals with personal data.

1. DEFINITIONS

Here we explain what we mean by specific words and names that we use in this policy.

Webshop:  The Web Shop livaxl.co.uk and every other by LivaXL appointed Web Shop, URL, or application.

Interaction : the use of functions in the Web shop like the Wish List, Checkout, Newsletter Sign Up, My Account, Auctions and Chat.

Web Shop Visitor:  a customer visiting the Web Shop for the first time that does  not  interact with the Web Shop.

Web Shop Customer : a customer who interacts with the Web Shop.

Account:  the account a customer must create through the Webshop to be able to place an order.

Privacy Policy and Cookie Statement:  LivaXL’s Privacy Policy and Cookie Statement.

2. LONG DESCRIPTION

2.1 Collection of personal data through Webshop

On our Webshop, we use the cookies and other tracking technologies.

From Webshop visitors , we might collect the following information depending on your cookie settings:

What?	Why?
Country Viewed products IP-address How you entered our Web Shop Where you leave our Web Shop With what kind of device you visit our Web Shop	To better understand Web Shop Visitors, to load the correct Web Shop to show relevant ads.

From Webshop customer , we collect the following information :

For Web Shop Customers, we collect the same information as for Web Shop Visitors, supplemented with information the customer shares with us, for example:

What?	Why?
Preferences in the Wish List Ordered products Contact information	Providing you with relevant product suggestions

Through the customer account , we collect the following information :

What?	Why?
First and last name E-mail address Password	To create and manage your account To counteract fraud, abuse and/or improper use of your account To show the products you have ordered in your account To optimise claims and to keep track of contact history concerning Web Shop orders and products offered by third parties

The data is saved at least as long as you have an account with LivaXL.

When you place an order , we collect the following information :

What?	Why?
Name E-mail address Delivery address Phone number Company name (if applicable) VAT number (if applicable) CoC (Chamber of Commerce) number (if applicable)	To keep you informed about the status of your orders To complete the order/agreement, amongst other things the delivery and so-called after-sales obligations. Billing To improve our service To handle questions and complaints To personalise marketing activities To place orders on behalf of a company
Company name (if applicable) Name Billing address Phone number Payment method	To be shown on the invoice To contact you concerning the finalisation of the order, billing or delivery To be able to receive payment and to optimise the checkout process To prevent fraud and hacking The selected method of payment and your IP-address are forwarded to our payment provider Adyen, after which they handle the payment

When you pay for your order , we collect the following data, which is also shared with our payment partners

List of our payment partners available on livaxl.co.uk:

• Paypal
• Visa
• MasterCard
• American Express
• Klarna ( https://cdn.klarna.com/1.0/shared/content/legal/terms/0/en_us/privacy )

What?

Why?

Email address Company name (if applicable) Name Billing address Delivery address Phone number Order value IP address Order number Device Method of payment

Shared with the selected payment partner; To send a payment notification via email; To assess the risk of fraud; To forward the order number via email in case of payment or cancellation of the order; To forward the order value and payment method so that the reception of the payment through the chosen payment method can be verified; To better our services in case of questions about payment, cancellation and refunds; To reduce errors during the payment process, making the experience of ordering more pleasant.

When you take part in an auction , you will need to, in addition to the information necessary to create an account, also create a so-called “bidder nickname”. Other customers can also see your bidder nickname.

This bidder nickname will be used in combination with your account- and order information for the following purposes:

• Managing and organising the auctions
• Combatting and checking for fraud, abuse and/or unintended use.

When you create your own Wish List in our Web Shop and add products to your Wish List while logged out they will remain on the list for 30 days.

Amongst other things, the following information might be gathered regardless of whether you are logged in or out depending on your cookie settings:

• IP address
• Web Shop browsing behaviour

If you add products to your Wish List while logged in you can always find them under Wish List in My Account.

This data is gathered for marketing purposes so that LivaXL can remember your Wish List when you return to the Web Shop.

2.2 Collection of personal data through reviews and customer satisfaction surveys

You can review products from the Web Shop via My Account . You can only review a product if you have purchased it.

When you leave a review the following data is gathered so that the order and the correct review can be linked to the correct email address.

What?	Why?
Name E-mail address Product Order number	To add the product reviews to the Web Shop To contact the customer in case of possible complaints

Through the Webshop you can review the Web Shop and (the service of) LivaXL . Here too, you must first have placed an order to be able to leave a review. To assess the service of LivaXL the following data is collected:

What?	Why?
Name Residence	Contact customer Complaint handling

Via the Web Shop you can leave a review by clicking the “Write a review” or similar link. After this you are forwarded to a third party Web Shop, one of LivaXL’s contract partners, that specialises in customer reviews. Through this website, you can place a review after you have agreed to the terms and conditions of the third party. This third party is responsible for the processing of your personal data. In this case,

You can leave a review about LivaXL via comparison sites that show LivaXL products and prices. To leave a review the following data is collected:

What?	Why?
Email address Name	Contact customers Complaint handling

For more information about the collected data you are referred to the privacy policy of the relevant other channel.

After you have placed an order with LivaXL or after you have had contact with LivaXL you can be approached to participate in a customer satisfaction survey . This survey is executed by an external party. If you participate in such a customer satisfaction survey, the following (personal) data will be processed:

What?	Why?
Contact information E-mail address and/or phone number Experiences with (departments of) LivaXL and/or affiliated businesses Information about a placed or delivered order IP-address	Research into customer service satisfaction concerning (departments of) LivaXL and/or affiliated businesses Improvement of service and processes Handling of questions and/or complaints Checking for abuse (e.g. multiple reviews/experiences by one and the same person)

2.3 Collection of personal data through our customer service department

Contact with customer service

If you have questions or complaints about a product you purchased from us via the Web Shop or about the service of LivaXL you can call us, e-mail us or chat with us. You can find the contact information in the Web Shop. It is also possible to use our online complaints form on the Web Shop. If you use the online form, we will ask for (at least) the following (personal) information:

What?	Why?
First and last name E-mail address Phone number Order number (optional/if applicable) Description of the nature of your complaint Chat feature : only first and last name, e-mail address and the subject of the chat	Handling complaints Provide information

Recording of interactions

Interactions with our customer service can be recorded for training-, evaluation- or quality purposes. In case a phone conversations is recorded, you will be informed of this the moment you contact our customer service by phone. The (personal) data that is recorded will only be used for the aforementioned purposes.

The recorded phone conversations are stored and secured in such a way that they are not accessible to unauthorized persons and they are never kept longer than needed for the specific purpose.

Third party service

LivaXL uses external parties for part of its customer service interactions.

Newsletters

You can apply for different newsletters, both general and personal. The personal newsletters are sent based on, for example, your personal details and order history, so we can send you more relevant newsletters. If you wish to receive the free digital newsletters sent by LivaXL and partners, we ask, among others, for the following (personal) information.

• Title
• First and last name
• E-mail address

You can unsubscribe from the newsletters at any time by logging into your account and unsubscribing. Besides that you can always use the unsubscribe-link in the newsletters.

2.4 Privacy of Children

LivaXL does not knowingly collect or use personal information from children younger than 18 years old. We do not knowingly allow children to order our products, communicate with us or use any of our online services. If you are a parent and become aware that your children have provided us with information, please contact us using one of the methods specified below and we will work with you to address this issue.

2.5 What are your rights?    

Under data protection legislation, you have rights including:

• Your right of access – You have the right to ask us for a copy of your personal information once every 12 months
• Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
• Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
• Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.’
• Your right to object to processing (only when based on consent) – You have the right to object to LivaXL processing under certain circumstances. 
• Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organization, or to you, in certain circumstances.
• Non – discrimination: you have the right not to be discriminated against for making use of any of your above rights. We may, however, offer you financial incentives permitted by law which can result in different prices, rates, or quality levels.

You are not required to pay any fare for exercising your rights. If you make a request, we have 45 days to respond to you. When exercising your right, we will request that you provide us with sufficient information to allow us to verify that you are the person whom we collected personal information about (“verifiable request”). You can do this by using the email address you used to place an order for example.

Do not sell right : subject to certain exceptions defined in applicable laws, you can request companies to stop selling your personal information and refrain from doing so in the future. LivaXL does not sell information (as per definition of the CCPA) and does not plan to do so in the future. You are provided with the option to opt-out from cookies as described in part 4.2. If you would however like to submit such a request or make use of any other of your rights, please send your request to LivaXL, Customer Support, 12200 Arrow Route, Rancho Cucamonga, CA 9173 or by email at info@livaxl.co.uk .

2.6 Data Processing within LivaXL

The LivaXL-concern has several offices worldwide. These offices work closely together. Employees in our offices only have access to personal data as far as this is required for them to do their job.

LivaXL takes measures to sufficiently protect your personal data. To achieve this, we use means that fit our activities, the nature and size of our company, and the sort of data we process. We do this to prevent unauthorized access to, adjustment, disclosure or loss of personal data.

We expect that you also contribute to the safekeeping of your personal data by keeping your login details (e-mail address and password) secret. Never share your login details with anyone and treat them with care.

LivaXL does only stores your information as long as necessary to achieve the purposes your information is used for, unless the data has to be stored longer due to legal requirements (such as a retention obligation). How long certain data is stored depends on the nature of the data and the purposes for which it is processed. The storage period can therefore differ per purpose.

Because of the global presence of LivaXL, we may share information about you and transfer it to countries in the world where we do business. It can happen that your data is processed outside of the United States of America. LivaXL makes sure that your data is well protected within the entire concern. While our products are available outside of the United States of America, including in the European Union, livaxl.co.uk is not designed to be accessed/used outside of the United States of America.

LivaXL might provide your personal data to trusted third parties which include:

• Affiliate companies: LivaXL being a group of entities, your data might be made available to other entities part of the LivaXL group
• Service Providers: your data might be transferred to various of our service providers such as delivery services, cloud storage, customer service, marketing, etc.
• Other entities: your data might be shared on demand with law enforcement entities, the government, legal representatives, etc.
• In the event of reorganization (merger, acquisition, etc.), your data might be shred with the newly formed entity.

Your data is shared with the aforementioned third parties for the following reasons:

• You have given your express consent for this; or
• The agreement you have with us needs to be executed; or
• Because LivaXL has a collaboration with another party in the context of improving our products and services; or
• An obligation by law; or
• To prevent or fight fraud or potential/suspected fraud;
• If necessary for the business management of LivaXL.

Some of the external companies we work with are based outside the United States of America. This means that the data can be stored on servers outside of Europe. Different legislations concerning personal data apply there. Third parties to which your data might be sent to is protected by appropriate measures including obligations binding on these companies and imposed to them by LivaXL.

This Privacy Policy and Cookie statement is not applicable to third party Web Shops that are linked to the Web Shop. Besides that the Privacy Policy and Cookie Statement is also not applicable to data collected by companies such as Google. You can adjust your preferences yourself in your Google account. Consult their  privacy policy  for this.

LivaXL can in no way be held accountable or responsible for the way in which third parties and companies deal with your (personal) data. LivaXL always advises that you read the Privacy Policy and Cookie Statements on the relevant Web Shops and from the relevant companies.

3. USE OF COOKIES

3.1 What are cookies?

As with many Web Shops, LivaXL uses cookies and files similar to cookies and technologies such as “web beacons” (hereafter: “Cookies”).

A Cookie is a small text file that is sent with the Web Shop page via your browser, it is then saved on a hard drive of your computer, phone or tablet.

Cookies are for example used to save passwords and personal settings, so that you don’t have to fill those in the next time you visit the Web Shop.

Below it will be explained how the Web Shop uses Cookies, where the Cookies come from and why they are used. For the optimization of our own ads and those from third parties the following data, amongst others, is collected:

• Purchased products
• Viewed products
• Order value
• How did the customer get on the Web Shop

In part 4.2, we will describe how Cookies can be rejected and removed.

3.1.1 Functional Cookies

LivaXL uses Cookies, such as Google Analytics to remember your chosen settings and entered data during your visit to our Web Shop. These Cookies make browsing our Web Shop easier because certain data does not have to be re-entered every time.

In addition, LivaXL can use Cookies that are necessary to make the Web Shop function well, even when you visit the Web Shop on your mobile phone or tablet.

3.1.2 A/B Testing Cookies

LivaXL continuously tests its Web Shop to be able to provide the best user experience. Because of that, LivaXL uses so-called A/B testing Cookies by third parties. With A/B tests, there are two different variants of the Web Shop, or parts of the Web Shop shown to visitors to determine which one works best. As such, this Cookie determines which version of the Web Shop you see.

3.1.3 Webshop Analysis Cookies

On the Web Shop, Cookies are used that keep track of which pages you have visited. This information is collected, amongst others, by web analysis services Google Analytics, Pingdom, Hotjar, Google Tag Manager, TVSquared, Zoovu, Zendesk, Content Square, Speedcurve and Clarity.

These web analysis services use Cookies to analyse how visitors use the Web Shop. The Cookies are used to save visitor information, such as the time the visit to the Web Shop took place, or whether the visitor has visited the Web Shop before and via which Web Shop the visitor ended up on the webpage.

To optimize the user- and customer experience of our Web Shop, LivaXL uses Hotjar Web Analytics Service. Hotjar can register mouse clicks, mouse movements and scrolling activities. Hotjar also collects information about visited webpages, taken actions, the country you are in, the device you are using and the browser you are working with. Hotjar does not collect any personally identifiable information (PII) that you do not enter voluntarily on the Web Shop. Hotjar also does not follow surfing behavior on Web Shops that do not use their services. Hotjar’s privacy statement contains a detailed explanation about how Hotjar is used:  https://www.hotjar.com/privacy . You can always choose to not have your information gathered by Hotjar when you visit our Web Shop, go to the ‘Opt-out’ page on the Hotjar Web Shop and click on ‘Disable Hotjar’ to do so.

The generated information about your Web Shop use is, in most cases, sent to the servers of the relevant web analysis services. The web analysis services use this information to evaluate how you use the Web Shop, to create reports about the Web Shop activities and to offer you other services pertaining to the use of the Web Shop and the internet. LivaXL uses the aggregated data from the reports for further optimising of the Web Shop.

Pingdom is a website performance monitoring tool. It helps us identify bugs and other performance issues. Pingdom does not collect any personally identifiable data. It collects anonymous data on website load times and load orders.

Google Analytics is a website behaviour analysis tool. It does not collect personally identifiable information. IP addresses are masked before they get stored by Google. Google Analytics collects and processes browsing behaviour, allowing us to identify bottlenecks on our website, and troubleshoot any potential issues our customers may encounter. In general, it helps us get a picture of how our customers interact with our website, and we can use that information accordingly to improve our platform.

Google Tag Manager is a tool that manages our cookie placement. It allows us to make quick changes to the way information is sent and received. (for example, we build our 3 ^rd party connections through this tool, and can and will block irrelevant cookies from there).

TVSquared is a tool we use to measure our offline branding efforts. It collects a limited set of browsing behaviour data, and combines that with our offline branding data, to measure the performance and effectiveness of our branding efforts.

Clarity is a similar tool to Hotjar. It has a similar use to Hotjar (mentioned above) in that it specializes in user behaviour on a deeper level. It measures clicks on the different elements on our pages, and collects recordings of user sessions (randomly selected and anonymous). This allows us to get an even better grip on potential issues on our website. Using this tool allows us to find flaws and potential areas that need improving, and allows us to test these improvements afterward.

LivaXL refers to the privacy policy of the relevant web analysis services in which is described how they deal with your (personal) data when their products and services, amongst which web analysis, are being used. .

3.1.4 Affiliate Cookies

On the Website, Affiliate Cookies are used to measure the effectiveness of ads placed on behalf of LivaXL on third party websites. This way the affiliate partner can be rewarded by LivaXL for their online advertising of LivaXL. Through these Cookies it can be checked via which affiliate partner you reached our Web Shop, whether ads are effective and if they did actually lead to a sale in our Web Shop. They do all of this without the exchange of personal data.

3.1.5 Retargeting Cookies

The Web Shop uses retargeting Cookies to show relevant ads to returning visitors of the Web Shop. With these Cookies, a profile of your surfing behavior can be built so that the ads correspond with your interests. The ads are shown on ad partners’ Web Shops and on social media. Cookies in this category are Google Ads, Bing Ads, Criteo Attentive and IntelliAd.

3.1.5.1 Criteo

Amongst other things, Criteo’s retargeting Cookies are used. For more information about the data Criteo collects, we refer you to the  Criteo Privacy Policy.

3.1.5.2 Google Ads & Analytics Remarketing

LivaXL uses Google Ads & Analytics remarketing services to show ads on third party Web Shops (including Google) to previous visitors of LivaXL. This can mean that we, for example, show ads to a visitor that has not completed their order, or has just completed their order. The ads can be text- or display ads within the Google Display Network.

All collected data is used in accordance with the Privacy Policy and Cookie Statement from LivaXL and Google’s privacy policy. You can set your ad preferences via the  Google Ad Preference page .

3.1.5.3 Retargeting Cookies third party Webshops

On third party Web shops (such as online marketplaces), retargeting can also happen. LivaXL Cookies are then used to show relevant ads to previous visitors of these other Web Shops.

3.1.5.4 Facebook, Instagram and Pinterest Advertising and analytics

LivaXL uses Pinterest Ads and Facebook Ads remarketing services to show ads on third party platforms (including Pinterest, Facebook and Instagram) to previous visitors of LivaXL. This can mean that we, for example, show ads to a visitor that has not completed their order, or has just completed their order. We share information with Pinterest, Facebook and Instagram from cookies set in the websites’ domains, whether or not you have a Facebook account or are logged in. Their purpose is to personalize content (including ads), measure ads, produce analytics and provide a safer experience, as set out in this Facebook Cookies Policy . All collected data (Email address, gender, location, first name and surname, phone number, date of birth, IP) is used in accordance with the Privacy Policy and Cookie Statement from LivaXL and Facebook’s privacy policy. You can adjust your ad preferences via the Facebook Ad preferences or Instagram Ad preferences .

3.1.5.5 RTB House

Amongst other things, RTB House’s retargeting Cookies are used. For more information about the data RTB House collects, we refer you to the RTB House’s Privacy Center.

3.1.6 Social Media Cookies

On the Web Shop, you can use (for example) social media buttons from Facebook, YouTube, Twitter, Pinterest and Google+.

As soon as you visit a page on the Web Shop that has social media buttons, your browser connects to the relevant social media provider. Through this, the provider obtains information about the pages on the Web Shop you visited with your IP-address.

If you are logged in to Facebook, YouTube, Twitter, Pinterest or Google+ during your visit to the Web Shop, your visit can be linked to your account. If you use the buttons, by clicking the Facebook ‘Like’-symbol for example, then the relevant information is sent to and saved by the relevant provider via your browser.

The purpose and scope of the data collected through social media buttons, as well as further processing, the further use and the duration of the storage, are exclusively determined by the providers of the buttons. You can read more about this in the privacy policies of the relevant providers.

3.1.7 Price Comparison Cookies

The Web Shop uses different avenues of advertisement. Aside from affiliates, another popular channel our customers like to use is Price Comparison Websites. These websites aggregate product lists from different websites and display them in a way the customer can easily compare stores, prices and service levels.

In order to determine the performance of these Price Comparison Websites, we send confirmation of the purchase (if made through their channel) and limited purchase information (amount of products, total transaction amount) to these partners. This allows us to monitor their performance and adjust accordingly. They do not collect personally identifiable information.

3.1.8 Email Cookies

On the livaxl.co.uk, Email Cookies are used to measure the effectiveness of commercial e-mails sent by LivaXL. This way we can measure effectiveness and performance of our e-mail campaigns and newsletters. All of this happens without collecting any personal information.

We currently work with an email cookie partner named Clang. We also work with Salesforce Marketing Cloud which will allow you greater control over how you receive notifications.

3.1.9 Data for recommending and optimizing the customer experience

To provide you with a personalized and optimized experience on livaxl.co.uk , we use general customer behavior and statistics. 

When you view a product on livaxl.co.uk , you will also see similar or related products listed under the headings “you may also like” or “recommended combinations”. These recommendations are related to products you are currently or have recently viewed. Additionally, you may see recommendations based on statistical data from customers who have previously purchased the item you are viewing. These recommendations are not personalized and are advertised to all customers who view the product. 

3.2 Accepting and Declining Cookies

When you enter livaxl.co.uk, a cookie banner appears at the bottom of our website. You can either accept all the cookies (Essential cookies, analytical cookies and marketing cookies) or chose to personalize settings. 

If you chose to personalize the settings, you will be able to choose to opt-in to analytical and marketing cookies. If you click on “save settings” without opting in to analytical or marketing cookies, only essential cookies will be used.

Essential cookies cannot be declined as they are strictly necessary to provide the website and its functionality (ex: to allow us to hold items in your cart, to keep your language preferences).

You can also accept or decline Cookies by adjusting your browser settings. Every browser is different, so LivaXL refers you to the information page of your browser or the user manual of your phone for the setting of your Cookie preferences.

If Cookies are completely switched off, it is possible that you cannot use all the functions of the Web Shop. If you use different computers at different locations, you must make sure that every browser is set to your Cookie preferences.

You can always remove Cookies from the hard drive in your computer, phone, or tablet. Consult the information page of your browser or the user manual of your phone or tablet to learn how to do this. Please note when you disable your cookies completely, it is possible that not all functionalities on the web shop can be used.

4. CHANGES TO THE PRIVACY POLICY

The contents of this Privacy Policy and Cookie Statement can be amended. The most current version can always be found on the LivaXL Web Shop. LivaXL advises that you regularly check this Privacy Policy and Cookie Statement, at least before you provide LivaXL with personal data.

5. HOW TO COMPLAIN?

If you have any concerns or questions about our use of your personal information, you can make a complaint to us at info@livaxl.co.uk

You can also complain to the competent local or federal authority depending on your place of resident if you are unhappy with how we have used your data.