Privacy Policy

Policy version: Monday 16th August 2021- V1.02

Loveiom.com (our website) is provided by KBH Limited (‘we’, ‘our’ or ‘us’). We are the controller of personal data obtained via our website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the IOM General Data Protection Regulation (IOM GDPR).

Given the nature of our website, we do not expect to collect the personal data of anyone under 13 years old. If you are aware that any personal data of anyone under 13 years old has been shared with our website please let us know so that we can delete that data.

This version of our privacy policy is primarily written for adults, including parents and guardians of child users.

This privacy policy is divided into the following sections:

  • What this policy applies to
  • Personal data we collect about you
  • How your personal data is collected
  • How and why we use your personal data
  • Marketing
  • Who we share your personal data with
  • How long your personal data will be kept
  • Transferring your personal data out of the IOM
  • Cookies and other tracking technologies
  • Your rights
  • Keeping your personal data secure
  • How to complain
  • Changes to this privacy policy
  • How to contact us

What this policy applies to

This privacy policy relates to your use of our website only.

Throughout our website we may link to other websites owned and operated by certain trusted third parties to make additional products and services available to you). Those third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to those third party websites, please consult their privacy policies as appropriate.

Personal data we collect about you

The personal data we collect about you depends on the particular activities carried out through our website. We will collect and use the following personal data about you:

  • your email address
  • details of any information, feedback or other matters you give us by phone, email, post or via social media
  • information about how you use our website and technology systems
  • If you do not provide personal data we ask for where it is indicated to be ‘required’ at the point of collection, it may delay or prevent us from providing services to you.

    We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.

    How your personal data is collected

    We collect personal data from you:

    • directly, when you enter or send us information, such as when you register for our newsletter, and
    • indirectly, such as your browsing activity while on our website; we will collect information indirectly using the technologies explain in the section on ‘Cookies and other tracking technologies’ below

    How and why we use your personal data

    Under data protection law, we can only use your personal data if we have a proper reason, e.g.:

    • where you have given consent
    • to comply with our legal and regulatory obligations
    • for the performance of a contract with you or to take steps at your request before entering into a contract, or
    • for our legitimate interests or those of a third party

    A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

    The table below explains what we use your personal data for and why.

    What we use your personal data for

    Our reasons

    Providing products and services to you

    To perform our contract with you or to take steps at your request before entering into a contract

    To enforce legal rights or defend or undertake legal proceedings

    Depending on the circumstances: —to comply with our legal and regulatory obligations —in other cases, for our legitimate interests or those of a third party, i.e. to protect our business, interests and rights or those of others

    Retaining and evaluating information on your recent visits to our website and how you move around different sections of our website for analytics purposes. This helps us to understand how people use our website so that we can make it more intuitive or to check our website is working as intended

    Depending on the circumstances: —your consent as gathered by other websites with tracking services` —see ‘Cookies and other tracking technologies’ below —where we are not required to obtain your consent and do not do so, for our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price

    Communications with you not related to marketing, including about changes to our terms or policies or changes to the products and services or other important notices

    Depending on the circumstances: —to comply with our legal and regulatory obligations —in other cases, for our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price

    Protecting the security of systems and data

    To comply with our legal and regulatory obligations We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, i.e. to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us

    Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures

    For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price

    Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, e.g. to record and demonstrate evidence of your consents where relevant.

    To comply with our legal and regulatory obligations

    Marketing our services to existing and former customers

    For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers See ‘Marketing’ below for further information

    External audits and quality checks, e.g. for the audit of our accounts

    For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards

    To share your personal data with members of our group and third parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency In such cases information will be anonymised where possible and only shared where necessary

    Depending on the circumstances: —to comply with our legal and regulatory obligations —in other cases, for our legitimate interests or those of a third party, i.e. to protect, realise or grow the value in our business and assets

    See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.

    Marketing

    We may use your personal data to send you updates (by email, text message, telephone or post) about our products and services, including exclusive offers, promotions or new products and services.

    We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly.

    You have the right to opt out of receiving marketing communications at any time by:

    We may ask you to confirm or update your marketing preferences if you ask us to provide further products or services in the future, or if there are changes in the law, regulation, or the structure of our business.

    We will always treat your personal data with the utmost respect and never sell it with other organisations for marketing purposes.

    For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.

    Who we share your personal data with

    We routinely share personal data with:

    • third parties we use to help deliver our products and services to you, e.g. payment service providers, warehouses and delivery companies
    • other third parties we use to help us run our business, e.g. website hosts and website analytics providers

    We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on them to ensure they can only use your personal data to provide services to us and to you.

    We or the third parties mentioned above may occasionally also need to share personal data with:

    • external auditors, e.g. in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations
    • professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
    • law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations
    • other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations

    If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

    How long your personal data will be kept

    We will not keep your personal data for longer than we need it for the purpose for which it is used.

    Transferring your personal data out of the IOM

    The EEA, IOM and other countries outside the EEA and the IOM have differing data protection laws, some of which may provide lower levels of protection of privacy.

    It is sometimes necessary for us to share your personal data to countries outside the IOM and EEA. In those cases we will comply with applicable IOM and EEA laws designed to ensure the privacy of your personal data.

    For example we will transfer your personal data to:

    • our service providers located outside the IOM

    As we are based in the IOM we will also transfer your personal data from the EEA to the IOM.

    We will also ensure all protections required by applicable IOM and EEA laws are in place before transferring personal data to any organisation or body (or its subordinate bodies) governed by public international law or set up by, or on the basis of, an agreement between two or more countries (international organisations).

    Under data protection laws, we can only transfer your personal data to a country outside the IOM/EEA or to an international organisation where:

    • in the case of transfers subject to IOM data protection law, the IOM government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the IOM GDPR.
    • in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR.
    • there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you, or
    • a specific exception applies under relevant data protection law

    Where we transfer your personal data outside the IOM we do so on the basis of an adequacy regulation or (where such is not available) a legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the IOM GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the IOM unless we can do so on the basis of an alternative mechanism or exception provided by IOM data protection law.

    Where we transfer your personal data outside the EEA we do so on the basis of an adequacy decision or (where such is not available) legally-approved standard data protection clauses issued further to Article 46(2) of the EU GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the EEA unless we can do so on the basis of an alternative mechanism or exception provided by applicable data protection law.

    Any changes to the destinations to which we send personal data or in the transfer mechanisms we use to transfer personal data internationally will be notified to you in accordance with the section on ‘Change to this privacy policy’ below.

    For further information about such transfers and the safeguards we employ, including to obtain a copy of the standard data protection clauses, please contact our Data Protection Officer (see ‘How to contact us’ below).

    Cookies and other tracking technologies

    A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our website. We use cookies on our website. These help us recognise you and your device and store some information about your preferences or past actions.

    Your rights

    You generally have the following rights, which you can usually exercise free of charge:

    Access to a copy of your personal data

    The right to be provided with a copy of your personal data.

    Correction (also known as rectification)

    The right to require us to correct any mistakes in your personal data

    Erasure (also known as the right to be forgotten)

    The right to require us to delete your personal data—in certain situations

    Restriction of use

    The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data

    Data portability

    The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations

    To object to use

    The right to object: —at any time to your personal data being used for direct marketing (including profiling) —in certain other situations to our continued use of your personal data, e.g. where we use your personal data for our legitimate interests.

    Not to be subject to decisions without human involvement

    The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you We do not make any such decisions based on data collected by our website.

    For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the IOM’s Information Commissioner on your rights under the IOM GDPR.

    If you would like to exercise any of those rights, please email, call or write to us—see below: ‘How to contact us’. When contacting us please:

    • provide enough information to identify yourself eg. Your email address and any additional identity information we may reasonably request from you, and
    • let us know which right(s) you want to exercise and the information to which your request relates

    Keeping your personal data secure

    We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.

    We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

    If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported byIOM Government and leading businesses.

    How to complain

    Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

    You also have the right to lodge a complaint with the Information Commissioner.

    The IOM’s Information Commissioner may be contacted at https://www.inforights.im/complaint-handling/how-to-make-a-complaint-to-the-information-commissioner/ or by telephone: +44 1624 693260.

    Changes to this privacy policy

    We may change this privacy policy from time to time—when we make significant changes we will take steps to inform you, for example via email or by a prominent link to a description of those changes on our website for a reasonable period.

    How to contact us

    You can contact our Data Protection Officer by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

    Our contact details are shown below:

    • [email protected]
    • 2nd Floor, European House, 22-24 Victoria Street, Douglas, Isle of Man, IM1 2LE
    • +44 330 223 4482