LIGHTHOUSE (UK) LIMITED – PRIVACY NOTICE

This privacy notice sets out how Lighthouse (UK) Limited (company registration no. 04414422) (“Lighthouse”) uses and protects any personal data that you give us when you use our website and services and/or deal with us. Lighthouse is committed to ensuring that your privacy is protected. 

Personal data is information about you. In running our services as a manufacturing business and looking after the people who use our services, we are allowed to collect and process personal data. But we have to have a good reason to do so, we have to look after it, and we have to make sure that your rights are respected.

This privacy notice explains how we do all of those things and provides some other information that will help you to understand why we need your personal data and what we plan to do with it.

1.  WHO ARE WE?  

Lighthouse is the company that is responsible for collecting, using and protecting your personal data. That makes us a “data controller”.

If you have any questions about this privacy notice or our data protection practices, please contact us using these contact details:

CONTACT DETAILS

Company name: Lighthouse (UK) Limited

DPO: Simon Ashley (Managing Director)

Email address: privacy@lighthouse.uk.com

Postal address: Unit 23, Charnwood Business Park, North Road, Loughborough, LE11 1LE

Lighthouse is part of a wider group, whose ultimate global owner is MAX Co. Ltd (registered in Japan). We also have a sister company registered in the Netherlands, Lighthouse Europe B.V. (company registration number 75812592), and distribution units across Europe and further afield (altogether the “Group”).

From time to time your personal data will be shared with other companies in the Group who are also data controllers. Each data controller is answerable to its local data supervisory authority (“Authority) for compliance with data protection rules. Depending on the “Region” which you are located in the relevant Authority will be:

As a UK registered company, the ICO is our primary data supervisory Authority and the Authority you should contact them in the first place if you are located in a Region outside of the above listed Regions. 

2.  WHAT PERSONAL DATA DO WE COLLECT?  

Any information that we need to use, which could allow an individual to be identified, or gives other information about someone identifiable, is personal data. Where the information cannot be connected to an identifiable individual it is anonymous data, not personal data.

There are different types of personal data about you which we might collect, use, store or transfer. We have grouped these together as follows, and have given some examples of the type of personal data which might be collected in each group:

• Identity Data could include your first name, family name, username or similar identifier, any different name that you are known by or were born with, whether you are married, your title, date of birth, gender, or company name
• Contact Data could include the address where you live, a different address for communications, deliveries or invoices, your email address(es), telephone number(s) or other user ID for messaging
• Financial Data could include bank account and payment card details or other information about your money
• Transaction Data could include details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data could include information related to you and any technology you use including your 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, printer details and information about other technology on the devices you use to access our website, applications or other platforms
• Profile Data could include your username and password, purchases or orders made by or from you, your interests, preferences, feedback and survey responses
• Usage Data could include information about how you came to and leave our website, and how you use our website, applications and other platforms
• Marketing and Communications Data could include your preferences in receiving marketing from us and your communication preferences.

We will not necessarily collect all of this information from everyone. In fact, we will only collect the minimum information that we need. Further on in this notice we explain what information we would be likely to collect depending on what we need it for. 

We are also allowed to collect, use and share Aggregated Data for any purpose. This might be something like statistics (the percentage of visitors to our website who click through to a second page) or demographic (the numbers of learners from different counties or regions). Aggregated Data could be made up from peoples’ personal data, but it would not be considered personal data. It will not directly or indirectly reveal your identity. But 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 only be used in the ways described in this privacy notice.

From time to time the personal data we collect may include, or allow us to infer, Special Categories of Personal Data about you (this might include 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 might also collect information about criminal convictions and offences of people that apply to work for us. We take special care of these categories of personal data and only collect and process them when it is absolutely necessary.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or for the purposes of an agreement we have with you, and you fail to provide that data when requested, we may not be able to carry out our legal responsibilities or what we have agreed to do. We might then have to cancel an arrangement or a service you have agreed with us but we will tell you at the time if that is going to happen.

3. HOW WE COLLECT YOUR PERSONAL DATA

We use different ways of collecting data from you and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data in conversations, by filling in forms or by communicating with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • place an order;
  • ask for information about our services;
  • contact us by phone, e-mail, post or via our website;
  • ask for information to be sent to you;
  • provide a service to a company in our Group;
  • other activities; or
  • give us feedback.
• Automated technologies or interactions. If you interact with our website, we will automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. The cookie policy on our website contains further information for website visitors.
• Generated Data. We may generate Transaction, Usage, Marketing and Communications Data about you, by way of records of the various different direct and automated interactions that you have with us.
• Third parties. We may receive personal data about you from various third parties as set out below:

1. the Group; 
2. Other referring organisations; and
3. search information providers and advertising platforms Google, Microsoftor Amazon some of which might be based outside the UK or the EU.

4. HOW WE USE YOUR PERSONAL DATA  

We will only use your personal data for the purposes which we collected it for. These include the following:

5. WHO WE SHARE YOUR PERSONAL DATA WITH

We may share your personal data with the parties set out below, to the extent necessary for the purposes set out in the table above.

• Internal Third Parties, including the other companies that form part of the Group.
• External Third Parties, including suppliers, any external distributors we work with in connection with our services and products, and other government or regulatory bodies. In an emergency we might share your personal data with the emergency services or other similar authorities.
• 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 notice.

If a situation arose where we were to share information with third parties (including those who are part of the Group), we will make sure that they look after your personal data and treat it with the same care that we do. We do not allow our third-party service providers to use your personal data for their own purposes and only allow them to process your personal data for specified purposes and in accordance with our instructions.

6.  WHAT OTHER COUNTRIES WE SEND PERSONAL DATA TO 

As set out above, we would not generally expect to transfer, store or process your personal data outside of the Regions (as defined above). Transfers between Group entities in these Regions are covered by adequacy decisions issued by the UK Secretary of State or EU Commission as applicable from time to time.

We will only transfer personal data outside one of the Regions where it is necessary to do so. All such transfers will be made using the safeguarding mechanisms required under the applicable data protection legislation.

If you have any particular concerns about the transfer of data overseas, or to specific jurisdictions, please make us aware of these and we will do what we can to respect your concerns.

7.  HOW WE PROTECT PERSONAL DATA

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. We only retain the absolute minimum amount of personal data necessary for us to provide our services to you in an efficient manner. 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.  HOW LONG WE KEEP PERSONAL DATA FOR 

We will only keep your personal data for as long as reasonably necessary for our purposes (as above) including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may keep your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To work out the appropriate period to keep your personal data, we think about 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 in other ways, and applicable legal, regulatory, tax, accounting or other requirements.

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 connection with our processing of your personal data including the right to receive a copy of the personal data we hold about you. These rights include 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:
  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • 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.
  • 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.

COMPLAINTS: If at any point you have concerns about anything contained in this Privacy Notice, the way in which we have given effect to your rights as detailed above, or anything else relating to the information we hold about you, you have the right to make a complaint to the relevant Authority for your Region. We would always ask you in the first instance to give us the opportunity to address any concerns that you may have, but if you want to pursue a formal complaint you can use the relevant Authority contact details listed above. 

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 could 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 could 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.