Privacy policy
- Privacy Policy General Context
The limited company Naxeris sprl (hereinafter referred to as “Lthy” or “the Data Controller”), a Belgian company registered under the RCS/BCE registration number: BE0826 779 597 , reachable at info@lthey.eu and domiciled at: 9, ch du pont de briques, 5100 Jambes, Belgium operates the websites lthy.eu and lthy.myshopify.com.
The purpose of the present policy is to inform Users of the website hosted at the following address: www.lthy.eu and lthy.myshopify.com , hereinafter referred to as "the website", in a transparent manner about the way in which personal data is processed by Lthy, collected and processed.
The term "User" refers to any user, whether natural or legal person, who visits or interacts with the website in any way.
As such, Lthy determines all technical, legal and organizational means and purposes for the processing of Users' personal data. Lthy undertakes to take all necessary measures to ensure the processing of personal data in accordance with the law of July 30, 2018, with regard to the protection of individuals with regard to the processing of personal data and the free movement of this data ( hereinafter referred to as the "Regulations").
Lthy is free to choose a natural or legal person who processes the personal data of the users upon request and on his behalf (hereinafter referred to as the "Processor"). Where appropriate, Lthy undertakes to select a Processor that offers sufficient guarantees with regard to the technical and organizational security measures for the processing of personal data, in accordance with the Law and the Regulations.
2. Shopify
Our store is hosted on Shopify Inc. They provide us with the online e-commerce platform that allows us to sell our services and products to you.
Your data is stored in Shopify's data storage system and databases, and in the general Shopify application. Your data is kept on a secure server protected by a firewall.
3 .Payment(s)
If you make your purchase through a direct payment gateway, then Shopify will store your credit card information. This information is encrypted in accordance with the data security standard established by the payment card industry (PCI-DSS). Information relating to your purchase transaction is kept for as long as necessary to complete your order. Once your order is finalized, the information relating to the purchase transaction is deleted.
All direct payment gateways adhere to the PCI-DSS standard, managed by the PCI Security Standards Council, which is the joint effort of companies such as Visa, MasterCard, American Express and Discover.
PCI-DSS requirements help ensure the secure processing of credit card data by our store and its service providers.
4.Processing of personal data
The use of the Website by Users may result in the communication of personal data. The processing of this data by Lthy, in its capacity as Controller, or by service providers acting on behalf of and on behalf of Lthy, will comply with the Law and the Regulations.
Personal data is processed by Lthy, in accordance with the following purposes, via:
- The use of cookies
- The subscription to the newsletter
- Making contact via the contact form
- When requesting information, any email sent to our customer service
- During each visit to the Website, your internet location (IP address), the browser used, the country and country code of your computer, the pages of the website you visited during your visit, the advertisements you clicked on and all searches you have performed.
- We may collect this information even if you do not have a User account with Lthy.
5. Cookies
A cookie is a small text file saved by a website's server in the browser of your computer or mobile device when you visit that website. Cookies contain a unique code that allows your browser to be recognized when you visit the website ("session cookie") or during future repeated visits ("permanent cookie"). Cookies can be placed by the server of the website you are visiting or by partners with whom this website works. The server of a website can only read the cookies that it has itself placed; it does not have access to any other information on your computer or on your mobile device. Cookies are stored on your computer or mobile device in your browser's directory. The content of a cookie usually consists of the name of the server that placed the cookie, an expiration date and a unique encrypted code. Cookies generally ensure easier and faster interaction between the visitor and the website. In addition, they help the visitor to navigate between the different parts of the website. Cookies can also be used to make the content of a website or the advertising on that site more relevant to the visitor and to tailor the website to the personal tastes and needs of the visitor.
The Sites place a cookie on your computer for the purposes of statistical analysis and site audience measurement and for the purposes of simplifying access to the site. This cookie records information relating to the navigation of visitors on the site. It stores information that you enter during your visit, namely certain visitor information about the visitor, such as the domain name and the host computer from which the visitor is browsing the Internet, the Internet Protocol (IP) address of the computer used, the date and time of the visitor's navigation on the Sites and the URLs from which the visitor came to the site.
6. Purposes of the processing of personal data
In accordance with Article 13 of the Regulations, the purposes of the processing of the personal data are communicated to the User and are as follows:
- Processing orders and deliveries
- Sending e-mails and newsletters about our services and products
- The constant improvement of the e-commerce platform and its functioning, as well as the improvement of your navigation.
7. Personal data likely to be processed
The User agrees, while visiting and using the Website, that Lthy collects and processes the following personal data according to the conditions and principles described in this Privacy Policy:
The data entered in the various contact forms: surname, first name, title, date of birth, potentially your VAT number, e-mail address, telephone number, billing address, delivery address.
Information related to your IP address
The data related to your payment is collected and managed according to your choice by one of the two payment platforms selected.
7.1 Right to erasure
The User has the right to obtain the deletion of his personal data as soon as possible in the cases stated in article 17 of the Regulations.
Where the Controller has disclosed the personal data and is required to erase it pursuant to the preceding paragraph, the Controller shall take reasonable steps, including technical ones, taking into account the available technologies and the implementation costs, to ensure that the other Controllers processing such personal data, notify that the data subject has requested the removal by these Controllers of any link to this personal data, or of a copy or reproduction thereof.
The two preceding paragraphs do not apply insofar as this processing is necessary:
- to exercise the right to freedom of expression and information;
- to comply with a legal obligation requiring processing provided for by Union or Member State law to which the Controller is subject, or to perform a task carried out in the public interest or a task covered by the exercise of public authority vested in the Controller;
- for the establishment, exercise or defense of legal claims.
In accordance with Article 19 of the Regulations, the Controller shall notify each recipient to whom the personal data have been disclosed of any deletion of the personal data or any restriction on the processing carried out, unless such communication proves impossible or requires disproportionate effort. The Controller will provide the data subject with information about these recipients upon request.
7.2 Right to restriction of processing
The User has the right to obtain the restriction of the processing of his personal data in the cases stated in article 19 of the Regulations.
In accordance with Article 19 of the Regulations, the Controller shall notify any recipient to whom the personal data have been disclosed of any restriction on the processing carried out, unless such communication proves impossible or requires disproportionate efforts. The Controller will provide the data subject with information about these recipients upon request.
7.3 Right to data portability
In accordance with Article 20 of the Regulations, Users have the right to receive personal data from Lthy in a structured, commonly used and machine-readable format. Users have the right to transfer this data to another Controller without Lthy obstructing this in the cases provided for by the Regulations.
When the User exercises his right to data portability in accordance with the previous paragraph, he has the right to obtain that personal data is sent directly from one Controller to another, where this is technically possible.
The exercise of the right to data portability does not affect the right to erasure. This right does not apply to processing that is necessary for the performance of a task carried out in the public interest or that falls under the exercise of official authority vested in the Controller.
The right to data portability does not affect the rights and freedoms of third parties.
7.4 Right to objection and automated individual decision-making
The User has the right at all times to object to the processing of his personal data due to his specific situation, including the automation of data performed by Lthy. In accordance with Article 21 of the Regulations, Lthy will no longer process personal data, unless there are legitimate and compelling reasons for the processing that override the interests and rights and freedoms of the User, or for the establishment, exercise or defense of legal claims.
When personal data is processed for prospecting purposes, the User has the right to object at any time to the processing of personal data concerning him or her for such prospecting purposes, including profiling to the extent that it is linked to such prospecting.
If the data subject objects to the processing for prospecting purposes, the personal data will no longer be processed for these purposes.
7.5 Right to file a complaint
The User has the right to file a complaint regarding the processing of his personal data by Lthy with the Data Protection Authority, competent for the Belgian territory. More information can be found on the website: https://www.autoriteprotectiondonnees.be.
A complaint must be submitted to the following addresses:
Data protection authority
Persstraat 35,
1000 Brussels
Phone. + 32 2 274 48 00
Email: contact@apd-gba.be
The User can also file a complaint with the court of first instance of his place of residence.
8. Limitation of Controller's Liability
The Website may contain links to other websites owned by third parties that are not linked to Lthy. The content of these websites and their respect for the Law and Regulations are not the responsibility of Lthy.
The holder of parental authority must give his explicit consent so that the minor under the age of 16 can disclose personal information or data on the website. Lthy strongly advises those exercising parental authority over minors to promote responsible and safe use of the Internet. The Data Controller cannot be held responsible for the collection and processing of information and personal data from minors under the age of 16 whose consent is not effectively covered by that of their legal parents or for incorrect data - in particular regarding the age entered by minors. Under no circumstances will personal data be processed by the Controller if the User indicates that he is younger than 16 years.
Lthy is not responsible for loss, corruption or theft of personal data, in particular caused by the presence of viruses or after computer attacks.
9. Transfer of data to third parties
Certain personal data is passed on to third parties and can be processed by third parties, such as our accountant, the Shopify platform but also the Belgian government.
One or more of these third parties may be located outside the European Economic Area ("EEA"). However, personal data will only be transferred to third countries that have an adequate level of protection.
The employees, managers and / or representatives of the aforementioned service providers or institutions, as well as the specialized service providers appointed by them, are obliged to respect the confidentiality of your personal data and may only use this data for the purposes for which it was provided.
Personal data may also need to be transferred due to an order or to comply with a specific legal obligation. In this case, Lthy will make every effort to inform you of this notification to other third parties in advance. However, you acknowledge and understand that in certain circumstances this may not always be technically or commercially feasible, or that legal restrictions may apply.
10. Technical and organizational measures
Lthy will take the technical and organizational measures to process the data at a sufficiently high security level and to protect the personal data against any destruction, loss, falsification, unauthorized access or notification to third parties by mistake, as well as any unauthorized processing of this data.
Lthy can under no circumstances be held liable for any direct or indirect damage caused by the incorrect or unlawful use of personal data by a third party.
11. Access by third parties
With a view to the processing of your personal data, we give our employees, employees and agents access to your personal data. We ensure a comparable level of protection by imposing contractual obligations on these employees, employees and agents, similar to those described in this Privacy Policy.
12. Governing Law and Jurisdiction
This Privacy Policy is exclusively subject to Belgian law. Any dispute will be submitted to the courts of the judicial district of Lthy's registered office (Namur)
13.Contact
For any question or complaint regarding this Privacy Policy, the User can contact the Data Controller at the following address: info@Lthy.com
Thank you for your business with us!