Privacy Policy

Léon H. Ltd is committed to safeguarding your privacy. Contact us at angel-de@riccardod56.sg-host.com if you have any questions or problems regarding the use of your Personal Data and we will gladly assist you.

By using this site or/and our services, you consent to the Processing of your Personal Data as described in this Privacy Policy. This Privacy Policy is a part of our Terms and Conditions of Use; by agreeing to Terms and Conditions you also agree to this Policy. In the event of collision of terms used in Terms and Conditions of Use and Privacy Policy, the latter shall prevail.

Table of Contents

1. Definitions used in this Policy

2. Data protection principles we follow

3. What rights do you have regarding your Personal Data

4. What Personal Data we gather and how it is collected

5. Why we collect your Personal Data and how we use it

6. Who else has access to your Personal Data

7. Promotional Communications

8. How we secure your data

9. Information about cookies

10. Contact information

Definitions

Personal Data – any information relating to an identified or identifiable natural person.
Processing – any operation or set of operations which is performed on Personal Data or on sets of Personal Data.
Data subject – a natural person whose Personal Data is being Processed.
Child – a natural person under 16 years of age.
“Léon H. XXI”, “we” “us” and “our” (either capitalized or not) – refer to Léon H. Ltd as the controller of your personal data, except otherwise stated in this Privacy Policy.
Digital Platform – refers to the user dedicated online platform serving Léon H. Ltd, reachable via Https://leonhxxi.com.

Data Protection Principles

We promise to follow the following data protection principles:

• Processing is lawful, fair, transparent. Our Processing activities have lawful grounds. We always consider your rights before Processing Personal Data. We will provide you information regarding Processing upon request.

• Processing is limited to the purpose. Our Processing activities fit the purpose for which Personal Data was gathered.

• Processing is done with minimal data. We only gather and Process the minimal amount of Personal Data required for any purpose.

• Processing is limited with a time period. We will not store your personal data for longer than needed.

• We will do our best to ensure the accuracy of data.

• We will do our best to ensure the integrity and confidentiality of data.

Data Subject’s rights

The Data Subject has the following rights:

1. Right to information – meaning you have the right to know whether your Personal Data is being processed; what data is gathered, from where it is obtained and why and by whom it is processed.

2. Right to access – meaning you have the right to access the data collected from/about you. This includes your right to request and obtain a copy of your Personal Data gathered.

3. Right to rectification – meaning you have the right to request rectification or erasure of your Personal Data that is inaccurate or incomplete.

4. Right to erasure – meaning in certain circumstances you can request for your Personal Data to be erased from our records.

5. Right to restrict processing – meaning where certain conditions apply, you have the right to restrict the Processing of your Personal Data.

6. Right to object to processing – meaning in certain cases you have the right to object to Processing of your Personal Data, for example in the case of direct marketing.

7. Right to object to automated Processing – meaning you have the right to object to automated Processing, including profiling; and not to be subject to a decision based solely on automated Processing. This right you can exercise whenever there is an outcome of the profiling that produces legal effects concerning or significantly affecting you.

8. Right to data portability – you have the right to obtain your Personal Data in a machine-readable format or if it is feasible, as a direct transfer from one Processor to another.

9. Right to lodge a complaint – in the event that we refuse your request under the Rights of Access, we will provide you with a reason as to why. If you are not satisfied with the way your request has been handled please contact us.

10. Right for the help of supervisory authority – meaning you have the right for the help of a supervisory authority and the right for other legal remedies such as claiming damages.

11. Right to withdraw consent – you have the right withdraw any given consent for Processing of your Personal Data.

What Personal Data we gather and how it is collected

Information you have provided us with

You may provide us with information:

• When you create an account online; 

• When you use our Digital Platform;

• When you purchase products or services on our Digital Platform or in our stores;

• When you visit our stores;

• When you contact our customer-services;
  

• When you participate in one of our events;

Depending on what you provide us with, such information may include:

• Your identity (including your first name, last name, gender, nationality);

• Your contact details (including your postal address(es), email address(es), phone number(s));

• Your personal status (including your title);

• Your purchases and repairs (including purchase history, order details);

• Your preferences (including your size);

• Certain payment information (including billing information, payment type or method, charge or credit card number);

• Other information you may provide by filling forms or by contacting us (including your feedbacks, or other communications with us).

We will inform you when your information is required in order to process your request, to respond to your queries or to provide you with our products and services. If you do not provide this information, then it may delay or prevent us from processing your request, responding to your query or providing products or services to you.
We hope to ensure that the personal data we possess are accurate at all times and therefore we encourage you to update your information in case any changes have occurred. We also may ask you to update your information from time to time.
We recommend that you only provide the data requested or necessary for your query.

Information automatically collected about you

We may collect information when you use our Digital Platform, such as your IP address or other browsing information (including browser, operating system, device model), through cookies or similar technologies placed on your device. Some cookies are required for the proper functioning of our Digital Platforms and other are used for analytics purposes which help us to provide you with more personalized and customized services and a better digital experience.
For more information about cookies and to know how you can edit your preferences, please read the section below “Cookies and other technologies we use“.

We may also collect information about you from third parties, such as a spouse who contacts us on your behalf or from your friends who provide us with your information in order to invite you to events you may be interested in.

If you provide personal data to us about someone else, you must ensure that you are entitled to disclose that information to us and that, without us taking any further steps required by data protection laws, we may collect, use and disclose such information for the purposes described in our Privacy Policy. For example, you should ensure the individual concerned is aware of the various matters detailed in our Privacy Policy. The individual must also provide the consents set out in this Privacy Policy in respect of how we will deal with their personal information.

Minimum age
We remind you that we do not collect, directly or indirectly, personal data from persons under the age of 16, without prejudice to any local law setting a different minimum age. We therefore ask you not to provide us with personal data of persons who do not meet this requirement.

Publicly available information
We might gather information about you that is publicly available.

Why we collect your Personal Data and how we use it

We collect and use your personal data based on one or many of the following legal basis:

• We have obtained your prior consent. Please be aware of your rights, consult diligently our “Data Subject’s rights” section.

• The processing is necessary in connection with any contract between Léon H. XXI and you (for example, when you make a purchase);

• We have a legitimate interest in carrying out the processing and that legitimate interest is not overridden by your interests, fundamental rights, or freedoms (for example, to prevent payment fraud);

• We have to process your personal data to comply with applicable laws and regulations.

Depending on the context, we may use your personal data in order to:

• provide you with the products or services you requested;

• conduct checks to identify you and verify your identity;

• send you Promotional Communications – with your prior consent (see section “Promotional Communications”);

• provide you after-sale services and manage refunds;

• respond to your queries, suggestions and requests, including your data subjects’ rights exercises;

• manage complaints and litigation;

• manage the events you registered and/or participated in;

• to detect, prevent and fight against any fraudulent or illegal activity, including to protect your transactions from payment fraud, to act against counterfeiting and against the resale of our products in violation of our terms and conditions of sale and/or outside our distribution network

• protect you, employees and other individuals in our stores as well as our property;

• manage the stock of certain types of rare products to allow a fair allocation of the products we sell;

• monitor and improve our Digital Platform;

• conduct statistical analysis, in particular to adapt our product offer (including the use of your nationality after anonymization);

• improve our products and services;

• respect our legal obligations, including providing information to regulatory bodies when legally required, including but not limited to the prevention and the fight against fraud, money laundering and the financing of terrorism.

We reserve the right to anonymise Personal Data gathered and to use any such data. We will use data outside the scope of this Policy only when it is anonymised.
We might process your Personal Data for additional purposes that are not mentioned here but are compatible with the original purpose for which the data was gathered. To do this, we will ensure that:

• • the link between purposes, context and nature of Personal Data is suitable for further Processing;

  • the further Processing would not harm your interests and

  • there would be appropriate safeguard for Processing.

We will inform you of any further Processing and purposes.

Promotional Communications

With your express prior consent, you may receive information concerning offers, services, products or events sent by Léon H. XXI (“Promotional Communications”).

We rely on your consent to process the personal data you provide to us for this purpose. Therefore, if you no longer wish to receive such information, you can withdraw your consent at any time (see the sections “Data Subject’s rights”).

We may ask you to confirm or update your preferences regarding Promotional Communications if you instruct us to provide further products and/or services in the future, or if there are changes in the law and regulation.

Who else can access your Personal Data

We only work with Processing partners who are able to ensure adequate level of protection to your Personal Data. We disclose your Personal Data to third parties or public officials when we are legally obliged to do so. We might disclose your Personal Data to third parties if you have consented to it or if there are other legal grounds for it.

We will not sell or lease your personal information to third parties unless we have your permission or are required by law to do so.

We may disclose your personal data only to the parties indicated below and for the following reasons: 

• We disclose your personal data to Léon H. XXI employees that need to have access to your personal data and are authorized to process them in order to achieve the aforementioned purposes and who are committed to confidentiality. 

• We may disclose your personal data to departments in charge of customer relationship, retail, e-commerce, communication, legal affairs, finance, internal audit, IT management and security for the purposes set out in our Privacy Policy and to provide you with a consistent level of service across Léon H. XXI. This may include providing you with the products and services that you have requested, improving the services provided and – with your consent – sending you Promotional Communications concerning offers, services, products or events (for such purpose, you may withdraw your consent at any time – see section “Data Subject’s rights”).
  For the specific purpose of combating payment fraud, your personal data is employed to process your order and to fight against online payment methods fraud attempts. As part of our legitimate interest to fight against fraud with payment methods, Léon H. XXI, acting as data controller, can transmit your financial information to an external service provider with a fraud detection tool in order to authenticate a payment. Such service provider is committed to confidentiality.

• We may also disclose personal data to third-party providers acting on behalf of Léon H. XXI and approved by Léon H. XXI.
  All such processing is based on our prior instructions set out in a binding contract that is compliant with the requirements of applicable law. Such disclosures are made for different purposes including:

  • IT development and support;

  • Hosting and carrying out marketing and business studies and marketing campaigns;

  • Verifying your information, authenticating payments and processing orders and payments, to third parties that provide credit reporting, payment or order fulfilment services;

  • Delivery services

  • Data quality management services (standardization, deduplication…)
    These providers are committed to confidentiality and are not permitted to use your personal data for any other purposes. We also require them to use appropriate security measures to protect your personal data. 

Part of those service providers are located outside outside the EU. We have taken steps to ensure all personal data is provided with adequate protection and that all transfers of personal data, including outside the EU are done lawfully. Where we transfer personal data outside of the EU to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an agreement which covers the EU requirements for the transfer of personal data outside the EU, such as the European Commission approved standard contractual clauses, or other binding safeguards authorised by the European Data Protection Supervisor (EDPS).

• We may be required by the binding requirements of an applicable law, or for the purposes of responding to legal proceedings or other lawful requests to disclose your personal data to authorities or third parties. 

• We may also disclose or otherwise process your personal data, in accordance with applicable law, to defend our legitimate interests (for example, in civil or criminal legal proceedings). For example, we may disclose such personal data as necessary to identify, contact or bring legal action against a person or entity who may be violating our Terms and Conditions of Sale and Use, or who may be causing injury to, or interfering with, other users of our Digital Platforms.

How we secure your data

We do our best to keep your Personal Data safe. We use safe protocols for communication and transferring data (such as HTTPS). We use anonymising and pseudonymising where suitable. We monitor our systems for possible vulnerabilities and attacks.

All your personal data is strictly confidential and will only be accessible, on a need-to-know basis, to duly authorized personnel of Léon H. XXI and third providers acting on our behalf with appropriate technical and organizational security safeguards.
Léon H. XXI has implemented security measures to protect your personal data against unauthorized access and use. We follow appropriate security procedures in the storage and disclosure of your personal data so as to prevent unauthorized access by third parties and to prevent your data being accidentally lost. We limit those who access your personal data to those who have a genuine business need to access it. Those who do access your data will be subject to a duty of confidentiality towards Léon H. XXI.

We also have procedures in place to deal with any suspected data security breach. We promise to notify suitable authorities of data breaches and promise to also notify you if there is a threat to your rights or interests, where we are legally required to do so. We will do everything we reasonably can to prevent security breaches and to assist authorities should any breaches occur. If you have an account with us, please note that you have to keep your username and password secret.
We also require those parties to whom we transfer your personal data to comply with the same. However, unfortunately, the transmission of information via the internet is not completely secure. Even though we try our best we cannot ensure the security of your personal data transmitted by you to us via the internet. Any such transmission is at your own risk and you acknowledge and agree that we shall not be responsible for any unauthorized use, distribution, damage or destruction of Your Information, except to the extent we are required to accept such responsibility under the law. Once we have received your personal data, we will use the security measures abovementioned.

Cookies and other technologies we use

We use cookies and/or similar technologies to analyse customer behaviour, administer the website, track users’ movements, and to collect information about users. This is done in order to personalise and enhance your experience with us.

A cookie is a tiny text file stored on your computer. Cookies store information that is used to help make sites work. Only we can access the cookies created by our website. You can control your cookies at the browser level. Choosing to disable cookies may hinder your use of certain functions.

We use cookies for the following purposes:

• Necessary cookies – these cookies are required for you to be able to use some important features on our website, such as logging in. These cookies don’t collect any personal information.

• Functionality cookies – these cookies provide functionality that makes using our service more convenient and makes providing more personalised features possible. For example, they might remember your name and e-mail in comment forms so you don’t have to re-enter this information next time when commenting.

• Analytics cookies – these cookies are used to track the use and performance of our website and services

• Advertising cookies – these cookies are used to deliver advertisements that are relevant to you and to your interests. In addition, they are used to limit the number of times you see an advertisement. They are usually placed to the website by advertising networks with the website operator’s permission. These cookies remember that you have visited a website and this information is shared with other organisations such as advertisers. Often targeting or advertising cookies will be linked to site functionality provided by the other organisation.

You can remove cookies stored in your computer via your browser settings. Please find below instructions about managing and disabling cookies, depending on your browser:

Internet Explorer
Go to Tools menu, then Internet Options.
Click on Confidentiality, then click on Advanced.
In the Cookies window, select your preferences.

Google Chrome
Click the Chrome menu, the upper right button.
Select Settings then click on Show advanced settings.
In the Privacy section, click the Content settings button.
Select your preferred option(s) in the Cookies section.

Firefox
Go to Tools then Options menu.
Click on the Privacy settings.
Select Use custom settings for history.
Select your preferred option(s) on the Accept cookies from sites section.

Safari
Click on Safari, then Preferences.
Click on the Privacy tab.
Go to Block cookies and select your preferred option(s).

Alternatively, you can control some 3rd party cookies by using a privacy enhancement platform such as optout.aboutads.info or youronlinechoices.com. For more information about cookies, visit allaboutcookies.org.

We use Google Analytics to measure traffic on our website. Google has their own Privacy Policy which you can review here. If you’d like to opt out of tracking by Google Analytics, visit the Google Analytics opt-out page.

Contact Information

Supervisory Authority
Website: https://ico.org.uk
Email: international.team@ico.org.uk
Phone: +44 1625 545 745

Changes to this Privacy Policy

We reserve the right to make change to this Privacy Policy. Last modification was made April 16, 2021.