Policy version: 08.12.2022
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https://www.yanametro.com/ (our website) is provided by Yana Metro trading as 1137 PRESS (‘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.
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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.
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We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).
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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.
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This version of our privacy policy is primarily written for adults, including parents and guardians of child users.
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What this policy applies to
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This privacy policy relates to your use of our website only.
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Throughout our website we may link to other websites owned and operated by third parties, for example social media sites. 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.
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Personal data we collect about you
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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:
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• your name, address and contact information, including email address and telephone number
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• any delivery addresses specified for an order
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• your billing information, transaction and payment card or other payment method information
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• details of any information, feedback or other matters you give to us by phone, email, post or via social media
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• your account details, such as username and login details
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• your activities on, and use of, our website
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• information about the services we provide to you
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• your contact history, purchase history and saved items
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• information about how you use our website and technology systems
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• your responses to surveys, competitions and promotions
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Where indicated, you must provide this personal data to use our website and the services on it unless we tell you that you have a choice.
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Sometimes you can choose if you want to give us your personal data and let us use it. Where that is the case we will tell you and give you the choice before you give the personal data to us. We will also tell you whether declining to share that personal data will have any effect on your use of our website or any services on it.
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We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
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How your personal data is collected
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We collect personal data from you:
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• directly, when you enter or send us information, such as when you register for an account on the website, contact us (including via email), send us feedback, purchase products or services via our website, post material to our website and complete customer surveys or participate in competitions via our website, and
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• indirectly, such as your browsing activity while on our website; we will usually collect information indirectly using the technologies explain in the section on ‘Cookies’ below
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How and why we use your personal data
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Under data protection law, we can only use your personal data if we have a proper reason, eg:
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• where you have given consent
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• to comply with our legal and regulatory obligations
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• for the performance of a contract with you or to take steps at your request before entering into a contract, or
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• for our legitimate interests or those of a third party
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A legitimate interest is when we have a business or commercial reason to use your personal data, 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).
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The information below explains what we use your personal data for and why.
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What we use your personal data for
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Create and manage your account with us.
Our reasons
For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price; and/or
To perform our contract with you or to take steps at your request before entering into a contract
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Providing products to you
Our reasons
To perform our contract with you or to take steps at your request before entering into a contract
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Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us
Our reasons
For our legitimate interests, ie to minimise fraud that could be damaging for you and/or us
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To enforce legal rights or defend or undertake legal proceedings
Our reasons
Depending on the circumstances:
—to comply with our legal and regulatory obligations
—in other cases, for our legitimate interests, ie to protect our business, interests and rights
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Customise our website and its content to your particular preferences based on a record of your selected preferences or on your use of our website
Our reasons
Depending on the circumstances:
—your consent as gathered by the separate cookies tool on our website —see ‘Cookies’ below
—where we are not required to obtain your consent and do not do so, for our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price
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Communications with you not related to marketing, including about changes to our terms or policies or changes to the products or other important notices
Our reasons
Depending on the circumstances:
—to comply with our legal and regulatory obligations
—in other cases, for our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price
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Protecting the security of systems and data used to provide the services
Our reasons
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, ie to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us
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Statistical analysis to help us understand our customer base
Our reasons
For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price
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Updating and enhancing customer records
Our reasons
Depending on the circumstances:
—to perform our contract with you or to take steps at your request before entering into a contract
—to comply with our legal and regulatory obligations
—where neither of the above apply, for our legitimate interests, eg making sure that we can keep in touch with our customers about existing orders and new products
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Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, eg to record and demonstrate evidence of your consents where relevant
Our reasons
To comply with our legal and regulatory obligations
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Marketing our services to existing and former customers
Our reasons
For our legitimate interests, ie to promote our business to existing and former customers
See ‘Marketing’ below for further information
How and why we use your personal data—Special category personal data
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We do not collect special category data (for example health information or details of criminal convictions), but if we were required to process such special category personal data, we will also ensure we are permitted to do so under data protection laws.
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How and why we use your personal data—sharing
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
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We will use your personal data to send you updates (for example by email or post) about our products and/or services, including exclusive offers, promotions or new products and/or services.
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Where you subscribe to our newsletter we rely on your consent to send you this marketing information. Where you create an account with us, 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 need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
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You have the right to opt out of receiving marketing communications at any time by:
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• contacting us at https://www.yanametro.com/contact, or
• using the ‘unsubscribe’ link in emails
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We may ask you to confirm or update your marketing preferences if you ask us to provide further products and/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 or share 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
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We routinely share personal data with:
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• The Rocket Science Group LLC d/b/a Mailchimp, who help us to deliver marketing emails and other information to you. They will be provided with your email address, your name, and your marketing preferences;
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• third parties we use to help deliver our products and/or services to you, eg payment service providers, warehouses and delivery companies; and/or
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• other third parties we use to help us run our business, eg 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.
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We or the third parties mentioned above occasionally also share personal data with:
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• our external auditors, eg in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations
• our and their 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 that have or may acquire control or ownership of our business (and our or their professional advisers) 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. The recipient of any of your personal data will be bound by confidentiality obligations
We will not share your personal data with any other third party.
Who we share your personal data with—further information
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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
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We will not keep your personal data for longer than we need it for the purpose for which it is used. Different retention periods apply for different types of personal data. Following the end of the of the relevant retention period, we will delete or anonymise your personal data.
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If you stop using your account we will delete or anonymise your account data after six years.
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Transferring your personal data out of the UK
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The UK and other countries outside the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.
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It is sometimes necessary for us to transfer your personal data to countries outside the UK. In those cases we will comply with applicable UK laws designed to ensure the privacy of your personal data.
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Under data protection laws, we can only transfer your personal data to a country outside the UK where:
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• in the case of transfers subject to UK data protection law, the UK 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 UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available here.
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• there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you, or
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• a specific exception applies under relevant data protection law
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Where we transfer your personal data outside the UK we do so on the basis of an adequacy regulation or (where this is not available) legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK 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 UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.
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Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy policy’ below.
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Cookies
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A cookie is a small text file which is placed onto your device (eg computer, smartphone or other electronic device) when you use our website. These help us recognise you and your device and store some information about your preferences or past actions.
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For example, we may monitor how many times you visit the website, which pages you go to, traffic data, location data and the originating domain name of your internet service provider. This information helps us to build a profile of our users. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually.
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For further information on our use of cookies, including a detailed list of your information which we and others may collect through cookies, please see below.
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For further information on cookies generally, including how to control and manage them, visit the guidance on cookies published by the UK Information Commissioner’s Office, www.aboutcookies.org or www.allaboutcookies.org.
Consent to use cookies and changing settings
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We will ask for your consent to place cookies or other similar technologies on your device, except where they are essential for us to provide you with a service that you have requested (eg to enable you to put items in your shopping basket and use our check-out process).
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You can withdraw any consent to the use of cookies or manage any other cookie preferences by using our privacy dashboard in the bottom left corner of each page (if you don't see it, please refresh the page). You can then adjust sliders to set your settings. It may be necessary to refresh the page for the updated settings to take effect.
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Our use of cookies
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The information below provides more details about the cookies we use and why:
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Origin Wix https://support.wix.com/en/article/cookies-and-your-wix-site
Name bSession
Duration 30 minutes
Purpose Used for system effectiveness measurement
Essential Cookie? Essential
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Origin Wix https://support.wix.com/en/article/cookies-and-your-wix-site
Name XSRF-TOKEN
Duration When the browsing session ends
Purpose Used for security reasons
Essential Cookie? Essential
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Origin Wix https://support.wix.com/en/article/cookies-and-your-wix-site
Name Fedops.logger.defaultOverrides
Duration 12 months
Purpose Used for stability/effectiveness measurement
Essential Cookie? Essential
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Origin Wix https://support.wix.com/en/article/cookies-and-your-wix-site
Name hs
Duration When the browsing session ends
Purpose Used for security reasons
Essential Cookie? Essential
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Origin Wix https://support.wix.com/en/article/cookies-and-your-wix-site
Name ssr-caching
Duration 1 minute
Purpose Used to indicate the system from which the site was rendered
Essential Cookie? Essential
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Origin Wix https://support.wix.com/en/article/cookies-and-your-wix-site
Name svSession
Duration 12 months
Purpose Used in connection with user login
Essential Cookie? Essential
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Origin Wix Amazon Web Services
Name AWSALBCORS
Duration 1 week
Purpose To provide load balancing functionality
Essential Cookie? Essential
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Third party access to the cookies
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The cookies we use will only be accessed by us and those third parties named in the table above for the purposes referred to in this cookie policy. Those cookies will not be accessed by any other third party.
How to turn off all cookies and consequences of doing so
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If you do not want to accept any cookies, you may be able to change your browser settings so that cookies (including those which are essential to the services requested) are not accepted. If you do this, please be aware that you may lose some of the functionality of our website.
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For further information about cookies and how to disable them please go to the guidance on cookies published by the UK Information Commissioner’s Office, www.aboutcookies.org or www.allaboutcookies.org.
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Your rights
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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, eg 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, eg where we use your personal data for our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims
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
The right to withdraw consents
If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time
You may withdraw consents by contacting us (see below ‘How to contact us’)
Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn
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 UK’s Information Commissioner on your rights under the UK GDPR.
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If you would like to exercise any of those rights, please complete a request form—available on our website at https://www.yanametro.com/contact - or email, call or write to us. See below: ‘How to contact us’. When contacting us please:
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• provide enough information to identify yourself (eg your full name, address and (if applicable) order number) and any additional identity information we may reasonably request from you, and
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• let us know which right(s) you want to exercise and the information to which your request relates
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Keeping your personal data secure
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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 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.
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How to complain
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Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
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You also have the right to lodge a complaint with the Information Commissioner in the UK. The UK’s Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.
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Changes to this privacy policy
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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 by including a prominent link to a description of those changes on our website for a reasonable period or by other means, such as email.
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How to contact us
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You can contact us by email at info@luminiferos.com 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.