THE LIFESTYLE GROUP

Privacy Policy

THE LIFESTYLE GROUP RESPECTS YOUR PRIVACY AND IS COMMITTED TO PROTECTING YOUR PERSONAL DATA. THIS PRIVACY NOTICE WILL INFORM YOU ABOUT HOW WE TAKE CARE OF YOUR PERSONAL DATA AND INFORM YOU ABOUT YOUR PRIVACY RIGHTS AND HOW THE LAW PROTECTS YOU.

Introduction

Welcome to The Lifestyle Group’s Privacy Notice.The Lifestyle Group.

This privacy notice is presented in a multi-level format, so you can skip to the specific sections listed below. Also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

Important information and who we are
Data we collect about you
How your personal data is collected
How we use your personal data
Disclosure of your personal data
International transfers
Data Security
Saving data
Your legal rights
Glossary

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this Privacy Notice

The purpose of this privacy notice is to provide you with information about how The Lifestyle Group collects and processes your personal data when you use this website or our services, including any data that you may provide through this website when you subscribe to our newsletter, purchase a product or service, or take part in the contest. This site is not intended for children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice that we may provide in certain cases where we collect or process your personal data, so that you are fully aware of how and why we use your data. This Privacy Notice supplements and does not replace any other notices.

The controller

This privacy notice is issued on behalf of each member of The Lifestyle Group, so when we mention “The Lifestyle Group”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in The Lifestyle Group responsible for processing your data.The Lifestyle Group, поэтому, когда мы упоминаем «The Lifestyle Group», «мы», «нас» или «наш» в этом уведомлении о конфиденциальности, мы имеем в виду соответствующую компанию в The Lifestyle Group The Lifestyle Group is the controller and is responsible for this website.

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing issues related to this privacy notice. If you have any questions about this privacy notice, including requests to exercise your legal rights, please contact the DPO using the contact information provided below.

Contact Information

Full name of the legal entity: The Lifestyle Group.

Name or position of the data protection specialist: The Lifestyle Group.

Email address: INFO@TLGPRIVATE.COM

Mailing address: 6365 COLLINS AVE MIAMI BEACH, FL 33141 / FIVE PALM JUMEIRAH NO. 1, PALM JUMEIRAH DUBAI

Phone number: +1 (786) 740-6393.

You have the right to file a complaint with the Information Commissioner’s Office (ICO) regarding data protection issues at any time.However, we would appreciate the opportunity to resolve your concerns before you apply for an ICO, so please contact us first.

Changes to the Privacy Notice and your responsibility to inform us of any changes

This version was last updated 1 on July 1 2024, 2024.

It is important that the personal data we store about you is accurate and up-to-date. Please keep us informed if your personal information changes during your relationship with us.

Third-party links

This website may contain links to third-party websites, plugins, and applications. Clicking on these links or enabling these connections may allow third parties to collect or share data about you. We have no control over these third-party websites and are not responsible for their privacy statements. When you leave our website, we recommend that you read the privacy notice of each website you visit.

2. HOW IS YOUR PERSONAL DATA COLLECTED?

We use various methods to collect data from and about you, including:

Direct interaction. You can provide us with your personal, contact, and financial information by filling out forms or contacting us by mail, phone, email, or otherwise. This includes personal information that you provide when you join The Lifestyle Group Club or place a request for services with The Lifestyle Group, as well as the circumstances in which you:

apply for our products or services;
create an account on our website;
subscribe to our services or publications;
request marketing information. send a newsletter;
participate in a contest, promotion, or survey; or
leave a review.

Automated technologies or interactions. As you interact with our site, we may automatically collect technical data about your equipment, actions, and browsing patterns. We collect this personal data using cookies, server logs, and other similar technologies. We may also receive technical data about you if you visit other websites that use our cookies. Please read our cookie policy cookie for more information.

Third parties or publicly available sources. We may receive personal information about you from various third parties and from publicly available sources, as described below:
Technical data from analytics providers such as Googlelocated outside the EU.
Identification and contact information from publicly available sources, such as Companies House and Electoral Register, located in the EU.

3. DATA WE COLLECT ABOUT YOU

Personal data or personal information means any information about an individual that can be used to identify that individual. This does not include data whose identity has been deleted (anonymous data).

We may collect, use, store and share various types of personal data about you, which we have grouped as follows:

Identification data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, and gender.
Contact details include billing address, delivery address, email address, and phone numbers.
Marketing and communication data includes your preferences for receiving marketing materials from us and our third parties, as well as your communication preferences.
Financial data includes bank account and payment card details.
Transaction data includes detailed information about payments to and from you, as well as other information about products and services that you have purchased from us.
Technical data includes your Internet Protocol (IP) address, your login information, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technologies on the devices you use to interact or access. this site.
Profile data includes your member identification number, purchases or orders made by you, your interests, preferences, reviews, and survey responses.
Usage data includes information about how you use our website, products and services.

We also collect, use and share aggregated data, such as statistical or demographic data, for any purpose. Aggregated data may be obtained from your personal data, but it is not considered personal data by law, since this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a particular website feature. However, if we combine or link aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data that will be used in accordance with this privacy notice.

We may collect any specific categories of personal data about you (including information about your race or ethnicity, religious or philosophical beliefs, sexual life, sexual orientation, political views, trade union membership, health information, and genetic and biometric data).

We do not collect any information about criminal records or misdemeanors.

If you have not provided any personal data

If we need to collect personal data by law or in accordance with the terms of a contract that we have entered into with you, and you do not provide this data upon request, we will not be able to fulfill the contract that we have or are trying to enter into with you. (for example, to provide you with goods or services). In this case, we may have to cancel your product or service, but we will notify you if this happens, at that time.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data if permitted by law. We will most often use your personal data in the following cases:

When we need to fulfill a contract that we intend to enter into or have entered into with you
If it is necessary for our legitimate interests (or the interests of a third party), and your interests and fundamental rights do not take precedence over these interests.
When we need to comply with legal or regulatory obligations.

As a general rule, we do not rely on consent as a legal basis for processing your personal data, except when sending you third-party marketing messages via email or text messages. You have the right to withdraw your marketing consent at any time by contacting us.

Purposes for which we will use your personal data

Below, in a table, we have provided a description of all the ways in which we plan to use your personal data, as well as what legal grounds we rely on for doing so. We have also identified what our legitimate interests are, where appropriate.

Please note that we may process your personal data for more than one legal reason, depending on the specific purpose for which we use your data. Please contact us if you need information about the specific legal basis on which we rely when processing your personal data, if more than one reason is indicated in the table below.

Goal/Activity

Data type

Legal basis/grounds for processing, including legitimate interest

To register you as a new member or client

(a) Identity
(b) Contact

Execution of the contract with you

To process and deliver your requests and orders, including:

(a) Execute requests placed by or on your behalf
(b) Manage payments, fees and charges
(c) Collect and refund money owed to us

(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications

(a) The performance of the contract with you
(b) Is necessary for our legitimate interests (to collect debts owed to us)

To manage our relationship with you, which will include:

(a) Notify you of changes to our terms and conditions or Privacy Policy
(b) Ask you to leave feedback or complete a survey

(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications

(a) The performance of the contract with you
(b) Is necessary to comply with a legal obligation
(c) Is necessary for our legitimate interests (to update our records and learn how customers use our products/services)

So that you can participate in a prize draw, contest, or complete a survey

(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications

(a) The performance of the contract with you
(b) Is necessary for our legitimate interests (to study how customers use our products/services, for their development and the development of our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and data hosting)

(a) Identity
(b) Contact
c) Technical

(a) Necessary for our legitimate interests (for running our business, providing administrative and IT services, network security, fraud prevention, and in the context of business reorganization or group restructuring)
(b) Necessary to comply with a legal obligation

To provide you with relevant website content and advertising, and to measure or understand the effectiveness of the ads we serve you.

(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical

It is necessary for our legitimate interests (to study how customers use our products/services, to develop them, to develop our business, and to inform our marketing strategy)

Use data analytics to improve our website, products/services, marketing, customer relationships, and experience.

(a) Technical
(b) Usage

Necessary for our legitimate interests (to identify customer types for our products and services, maintain the relevance and relevance of our website, develop our business, and shape our marketing strategy)

To give you suggestions and recommendations about products or services that you might be interested in.

(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile

Necessary for our legitimate interests (for the development of our products/services and the development of our business)

Marketing

We strive to provide you with a choice regarding certain types of use of personal data, especially in the field of marketing and advertising:

Special offers from us

We may use your identification, contact, technical, usage, and profile information to form an idea of what we think you might need or need, or what you might be interested in. This is how we decide which products, services, and offers you might be interested in (we call it marketing).

You will receive marketing communications from us if you have requested information from us or placed a request with us or purchased goods or services from us, or if you have provided us with your data when participating in a contest or registering for a promotion and, in each case, you have not refused to receive this marketing information.

Third-party marketing

We will obtain your express consent before transferring your personal data to any company outside The Lifestyle Groupfor marketing purposes.

Not taking part

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

If you opt out of receiving these marketing communications, this will not apply to personal data provided to us as a result of purchasing the product/service, experience using the product/service, or other transactions.

Changing a goal

We will only use your personal data for the purposes for which we collected it, unless we reasonably believe that we need to use it for another reason, and that reason is compatible with the original purpose. If you would like an explanation of how processing for a new goal is compatible with the original goal, please contact us.

If we need to use your personal data for unrelated purposes, we will notify you and explain the legal basis that allows us to do so.

Please note that we may process your personal data without your knowledge or consent in accordance with the above rules, if required or permitted by law.

5. DISCLOSURE OF YOUR PERSONAL DATA

We may need to share your personal data with the parties listed below for the purposes set out in the table in point 4 above.

Internal third parties, as indicated in the Glossary.
External third parties, as indicated in the Glossary.
Third parties to whom we may sell, transfer, or merge a portion of our business or assets. In addition, we may seek to acquire other companies or merge with them. If there are changes in our business, the new owners may use your personal data in the same way as indicated in this privacy Notice.

We require all third parties to respect the security of your personal data and treat it in accordance with the law. 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 specific purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

We share your personal data within The Lifestyle Group. This involves transferring your data outside the European Economic Area (EEA).

Many of our external third parties are based outside the European Economic Area (EEA), so their processing of your personal data will involve data transfers outside the EEA.

When transferring your personal data outside the EEA, we ensure a similar degree of protection by applying at least one of the following safeguards:

We only transfer your personal data to countries that, in the opinion of the European Commission, provide an adequate level of personal data protection.
If we use certain service providers, we may use special contracts approved by the European Commission that provide personal data with the same protection as in Europe.
If we use the services of providers located in the United States, we may share data with them if they are part of a Privacy Shield that requires them to provide similar protection for personal data transmitted between Europe and the United States. For more information, see the section ” European Commission: EU-US Privacy Shield.

Please contact us if you would like more information about the specific mechanism we use when transferring your personal data outside the EEA.

7. DATA SECURITY

We have taken appropriate security measures to prevent accidental loss, use or unauthorized access to, alteration or disclosure of your personal data. In addition, we restrict access to your personal data to those employees, agents, contractors and other third parties who have a business need to do so. They will process your personal data only in accordance with our instructions and are required to maintain confidentiality.

We have developed procedures to respond to any suspected breach of personal data and will notify you and any applicable regulatory authority of the breach if we are required by law to do so.

8. DATA STORAGE

How long will you use my personal data?

We will only store your personal data for as long as it is necessary to fulfill the purposes for which we collected it, including meeting any legal, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we take into account the scope, nature and sensitivity of personal data, the potential risk of harm resulting from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and the possibility of achieving these goals in other ways, as well as applicable legal requirements.

By law, we are required to keep basic information about our customers (including contact details, identity details, financial and transaction details) for seven years after they cease to be customers, for tax purposes.

In some circumstances, you may ask us to delete your data: for more information, see the “Request for Deletion” section below.

In some circumstances, we may depersonalize your personal data (so that it is no longer 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

In certain circumstances, you have rights under data protection laws with respect to your personal data. To learn more about these rights, see point 10 below:

Request access to your personal data.
Request correction of your personal data.
Request the deletion of your personal data.
Object to the processing of your personal data.
Request restriction of the processing of your personal data.
Request the transfer of your personal data.
Right to withdraw consent.

If you would like to exercise any of the rights described above, please contact us.

No fee is usually required

You will not have to pay a commission for accessing your personal data (or for exercising any other rights). However, we may charge a reasonable fee if your request is manifestly unfounded, repetitive, or excessive. Alternatively, we may refuse to grant your request in such circumstances.

What we might need from you

We may need to request specific information from you that will help us verify your identity and ensure your right to access your personal data (or exercise any other rights you have). This is a security measure that ensures that personal data is not disclosed to anyone who is not entitled to receive it. We may also contact you and ask for additional information on your request to speed up our response.

Response time

We try to respond to all legitimate requests within one month. Sometimes it can take more than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

10. GLOSSARY

Legal basis

Legitimate interest means that our business is interested in running and managing our business so that we can provide you with the best service/product, as well as the best and most secure experience. Before we process your personal data in our legitimate interests, we must take into account and balance any potential impact on you (both positive and negative) and your rights. We do not use your personal data for activities in which our interests prevail over our influence on you (unless we have your consent or otherwise required or permitted by law). You can get more information about how we assess our legitimate interests in relation to any potential impact on you in relation to specific actions by contacting us.

Performance of a contract means the processing of your data if this is necessary for the performance of a contract to which you are a party, or for taking measures at your request prior to the conclusion of such a contract.

Compliance with legal or regulatory obligations means processing your personal data if necessary to comply with the legal or regulatory obligations to which we are subject.

Third parties

Internal third parties

Other companies in The Lifestyle Group that act as joint supervisors or handlers, based in MIAMI and DUBAI, and provide:The Lifestyle Group, действующие в качестве совместных контролеров или обработчиков, базирующиеся в MIAMI и DUBAI и предоставляющие:

services in accordance with the contract that we are about to conclude or have already concluded with you.
IT and system administration services, as well as management reporting.

External third parties

Franchise partners acting as joint supervisors or processors who may provide services in accordance with a contract that we are about to enter into or have already entered into with you.
Service providers that act as processors that provide IT and management systems.