Introduction and background
The purpose of this policy is to outline how Lux Voyage has established measures to protect your privacy and information rights.
We recognise that you have rights as a ‘data subject’, and that we have an obligation to uphold these.
This privacy notice aims to remind you of your rights, and outlines how we maintain these rights. In particular, it outlines:
How we collect and process your information
Why we do this
How you can exercise your rights;
Who to contact in the event you’re unhappy with our performance.
Depending on why we have collected your information, your information rights could include:
Right to be informed
This encompasses the obligation for us to be transparent in how we collect and use your personal data.
Right of access
You have the right to access your personal data and supplementary information.
Right to rectification
If the information we hold on you is inaccurate or incomplete, you can request we correct this.
Right to erasure
You can request we delete or remove personal data where there is no compelling reason us to continue processing.
Right to restrict processing
You have the right to request we cease processing your data, if:
You consider it inaccurate or incomplete.
Where you object to processing and we are considering whether we still have a legitimate interest to process it.
Where we don’t need the data for the original reason we collected it, but may need it to support a legal claim
Right to data portability
Where you have consented to our processing your data, or where the processing is necessary for us to deliver a contract, you can request a copy of that data be provided to a third party in electronic form.
Right to object
You have the right to object to our processing under certain circumstances. For example, you can object to:
direct marketing (including profiling); and
processing for purposes of scientific/historical research and statistics
Rights relating to automated decision making including profiling
Where we apply automated decision making, we must:
give you information about the processing;
introduce simple ways for you to request human intervention or challenge a decision;
carry out regular checks to make sure that our systems are working as intended
Information related to automated decision making is contained later in this notice.
Information we collect Please find below a summary of the information we collect and how we use this to deliver services to you.
Information we collect
From the documentation – please include information type and where it originates
Why we collect this
From the documentation –please refer to the lawful basis for processing and expand with a description if this is a legitimate interest.
Please also make clear Whether the provision of personal data is part of a statutory or contractual requirement or obligation and the possible consequences of failing to provide the personal data
How we process this
From the documentation – please ensure this is in plain English
Transfer of data
Please provide details of who information is shared with and why, including transfers overseas, from the documentation. The table above can be replicated if necessary, with an additional column on ‘transfer overseas’
Retention of data
Please include details of the retention policy, as outlined in your documentation. For example: > retains information for seven (7) years from our point of last contact. We hold this information to support our legal and regulatory requirements. If you object to this retention, please contact us – details provided in the ‘Contact’ section.
Securing your information
Information and data security are important to us. Lux Voyage applies technical and organisational security measures in line with industry good practices.
We recognise that you may have questions on how we process and/or store your data, or may want to change either the data we hold on you or how we communicate with you in the future. If you have given consent for processing, you are free to withdraw that consent. To let us know this is the case > If you have any questions in respect of this notice, or would like to exercise your rights as a data subject (for example, to correct data or to exercise your right to access): •
Lux Voyage, as data controller, can be contacted as follows: