Privacy policy

LUNESI LTD – Privacy Policy

LUNESI LTD (company type: private limited company) is a company registered under the laws of England and Wales, with company number 15497453 and registered office at 128 City Road, London, United Kingdom, EC1V 2NX ("Lunesi", "we", "us", or "our").
The website https://lunesi.co.uk/ (hereinafter the “Website”) is owned and operated by Lunesi.

Lunesi respects your privacy and is committed to protecting your personal data. This privacy notice (the “Policy”) explains how we process your personal data when:

You visit our Website (regardless of your location);
You make a purchase on our Website;
You interact with us on social media;
You contact us with complaints, suggestions, etc.;
You request a refund or return for items purchased through our Website;
We inform you about updates to this Policy or other Lunesi legal documents (such as Terms of Use, Terms and Conditions, etc.);
We inform you about your privacy rights and how the law protects your data;
We inform you about promotions, loyalty programs, and other similar offerings.

We do not sell your personal data. By using the Website, you consent to our processing of your personal data as described in this Policy. If you do not accept the terms of this Policy, please refrain from using the Website.

In this Policy, “you” or “user” refers to any person visiting our Website or otherwise interacting with us as described above.

Please refer to the glossary at the end of this Policy for definitions of certain terms used.

IMPORTANT INFORMATION AND WHO WE ARE
THE DATA WE COLLECT
HOW YOUR PERSONAL DATA IS COLLECTED
HOW WE PROCESS YOUR PERSONAL DATA
DISCLOSURES OF YOUR PERSONAL DATA
INTERNATIONAL TRANSFERS
DATA SECURITY
DATA RETENTION
YOUR LEGAL RIGHTS
GLOSSARY
COOKIE POLICY

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this Policy

This Policy provides information on how Lunesi collects and processes your personal data through your use of the Website, including any data you may provide when you sign up for our newsletter, purchase a product, enter a competition, and so on.

The Website is not intended for children, and we do not knowingly collect data relating to children.

Please read this Policy together with any other privacy or fair processing notices we may provide on specific occasions, so you are fully aware of how and why we are using your data. This Policy supplements other such notices and is not intended to override them.

Controller

Lunesi acts as the controller of your personal data and is responsible for its protection. In some cases, we may engage third-party processors—such as delivery companies or software providers—to help fulfill our services. These processors are bound by this Policy and our internal data protection rules, and are required to sign data processing agreements.

Contact Details

Company Name: Lunesi Ltd
Company Number: 15497453
Email: info.lunesibeauty@gmail.com
Address: 128 City Road, London, United Kingdom, EC1V 2NX

Complaints

You have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK data protection authority (www.ico.org.uk). However, we encourage you to contact us first so we can address your concerns directly.

Changes to the Policy and Your Duty to Inform Us of Changes

This Policy was last updated on August 19th, 2024. If we make updates, we will notify you 30 days before the new version takes effect. You will not be required to give additional consent; the new version will take effect automatically 31 days after notification. If you do not agree with the changes, you must inform us. Continued use of the Website will be interpreted as acceptance of the revised Policy.

You are responsible for ensuring that the personal data we hold is accurate and current. Please notify us of any changes during your relationship with us.

Third-Party Links

Our Website may contain links to third-party websites, plug-ins, and applications. These sites may collect or share your data independently. We are not responsible for their privacy practices and encourage you to review their privacy policies.

2. THE DATA WE COLLECT

Personal data (or personal information) refers to any information about an individual from which they can be identified. It does not include anonymized data.

We may collect, use, store, and transfer different types of personal data, grouped as follows:

Identity Data: First name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender.
Contact Data: Billing, residential, business, and delivery addresses, email address, phone numbers.
Financial Data: Bank details, PayPal or other payment account data, payment card information.
Transaction Data: Payment history and records of purchases.
Technical Data: IP address, login information, browser and version, time zone, location, browser plug-ins, device information, operating system.
Profile Data: Account information, purchase history, preferences, feedback, and social media interactions.
Usage Data: Information on how you use the Website.
Marketing and Communications Data: Preferences for receiving marketing and communication preferences.

We also collect Aggregated Data—statistical or demographic data derived from your personal data but not linked directly to your identity. If such data is combined in a way that identifies you, we treat it as personal data.

Failure to Provide Personal Data

If you fail to provide data that we require by law or to perform a contract, we may not be able to fulfill the contract and may need to cancel a service or order. We will notify you if this is the case.

3. HOW YOUR PERSONAL DATA IS COLLECTED

We collect your data in several ways:

Direct Interactions
You may give us your data by filling in forms on the Website or by contacting us via email, phone, post, or social media. This includes when you:

Create an account
Make a purchase
Subscribe to our newsletter
Request marketing
Enter a competition or survey
Provide feedback
Submit a return/refund request
Make complaints or suggestions
Receive updates to our legal terms

By taking any of these actions, you consent to our collection and processing of your personal data in accordance with this Policy.

Automated Technologies
As you use our Website, we may collect Technical Data via cookies, server logs, or similar technologies. See our Cookie Policy for more information.

Third Parties or Public Sources
We may receive personal data from:

Analytics providers (e.g., Google, Facebook)
Data brokers or aggregators (e.g., Facebook, Instagram, Gmail)
Public databases (e.g., Companies House, Electoral Register)
Third-party service providers (e.g., PayPal, Shopify, Judge.me)

4. HOW WE PROCESS YOUR PERSONAL DATA

We use your personal data only when the law allows. Most commonly, we process your data when:

You have given consent;
It is necessary to perform a contract;
It is in our legitimate interests (and your rights do not override those interests);
We need to comply with legal or regulatory obligations.

We generally do not rely on consent as the sole legal basis for processing—except for sending third-party marketing communications. You may withdraw your consent to marketing at any time by contacting us.

Purposes for Which We Will Use Your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use your personal data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Notifying you about changes to our terms or Policy; and asking you to leave a review or take a survey.
Lawful basis for processing:
(a) Performance of a contract with you.
(b) Necessary to comply with a legal obligation.
(c) Necessary for our legitimate interests (to keep our records updated and to study how our users use our products/services).
To enable you to partake in a promotion, prize draw, competition or complete a survey.
Lawful basis for processing:
(a) Performance of a contract with you.
(b) Necessary for our legitimate interests (to study how users use our products/services, to develop them and grow our business).
To administer and protect our business and our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
Lawful basis for processing:
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring).
(b) Necessary to comply with a legal obligation.
To deliver relevant Website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
Lawful basis for processing:
(a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).
To use data analytics to improve our Website, services, marketing, customer relationships and experiences.
Lawful basis for processing:
(a) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy).
To make suggestions and recommendations to you about services that may be of interest to you.
Lawful basis for processing:
(a) Necessary for our legitimate interests (to develop our products/services and grow our business).

All personal data we collect and use from you is stored and analysed for the above purposes only. We store and process your personal data only for as long as permitted by United Kingdom law.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We also value your privacy and the information you consent to share in relation to our SMS marketing service. We use this information to send you text notifications (regarding your order, including abandoned checkout reminders), text marketing offers, and transactional texts, including requests for reviews from us.

Messengers

To communicate with you under this Policy, we may use messaging apps such as Telegram, WhatsApp and others. Please be aware that we do not share your data with these messengers; instead, we use them to send you information in accordance with this Policy. You can review the policies of some messaging services:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us, or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will obtain your express opt-in consent before we share your personal data with any third-party company for marketing purposes. If we do ask for your consent, it will only be in relation to carefully selected third parties who we think may be of interest to you due to their close connection with the beauty industry.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links in any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service and/or goods purchase, service experience or other transaction.

Our Website uses cookies to keep track of items you put into your shopping cart, including when you have abandoned your checkout. This information is used to determine when to send cart reminder messages via SMS.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

3.6. Through browser settings, you can choose which cookie files to accept and which ones to reject. These settings directly depend on the browser used by you:

Cookie settings in Chrome
Cookie settings in Firefox
Cookie settings in Internet Explorer
Cookie settings in Safari

Change of purpose

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

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

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

5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table above.

- External Third Parties as set out in the glossary.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.
- We only allow External Third Parties to handle your information if we are satisfied that they take appropriate measures to protect your personal information.

Alternatively, we may seek to acquire other businesses, merge with them or we may be sold to another business. If a change happens to our business, then we may pass your personal data to the new owners and the new owners may use your personal data in the same way as set out in this Policy.

We require all third parties to respect the security of your personal data and to 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 permit them to process your personal data for specified purposes and in accordance with our instructions.

We or the External Third Parties occasionally also need to share your information with certain recipients who will be bound by confidentiality obligations as follows:

- our or their external auditors;
- our or their professional advisors (such as lawyers and other advisors);
- law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal and regulatory obligations; and
- other parties that have or may acquire control or ownership of our business (and our or their professional advisors) 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 such information will be anonymised, but this may not always be possible.

Personal data that you provide to those parties listed above or other third parties may be sent to us so that we can deliver our products and services effectively. Your personal data may also be accessed by third-party applications, such as gadgets or extensions. Any personal data, when you enable such a third-party application, is processed under the Policy. Any information collected by a third-party application provider is governed by their privacy policies.

We may disclose your personal data with our social media network providers and any comments, statuses, updates, likes, tweets, etc. that you voluntarily share with us through our social media networks may appear on our Website or social media channels in the designated areas that show activity on our Website, social media pages or profiles.

We may also share your non-personal, aggregated information with the parties listed above.

6. INTERNATIONAL TRANSFERS
Some of our External Third Parties may be based outside the United Kingdom so their processing of your personal data will involve a transfer of data outside the United Kingdom.

Whenever we transfer your personal data out of the United Kingdom, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by United Kingdom.
- Where we use certain service providers, we may use specific contracts approved by the authority body of United Kingdom which give personal data the same protection it has in United Kingdom.
- Where we use providers based elsewhere, for example in the USA, we may transfer data to them if they have signed up to standard contractual clauses and the international data transfer addendum.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the United Kingdom.

7. DATA SECURITY
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. 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.

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access the Website you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

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. DATA RETENTION

How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We may retain 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 determine the appropriate retention period for personal data, we consider 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 through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

We reserve the right to make adjustments to the above periods that may result as a result of any orders, laws, or regulations issued by any governmental, legislative, or regulatory body with jurisdiction over us.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

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

You have a right at any time to request any of the following:

View or access the personal data we have collected about you, if any.
Change or correct any personal data we have collected about you.
Request us to delete any personal data we have collected about you.
Express any concern you have about our use of your personal data.

Under certain circumstances, you have rights under data protection laws in relation to your personal data 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 your 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 our 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 your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request 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, 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.
Right to 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.

If you wish to exercise any of the rights set out above, please contact us.

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 may 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 will respond to your request to exercise these rights within a reasonable time. We try to respond to all legitimate requests within one month. Occasionally it may 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.

10. GLOSSARY

LAWFUL BASIS

Consent means processing your data where you have provided us with your explicit consent.

Legitimate Interest means processing your data in the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

External Third Parties means:

service providers acting as processors who provide IT and system administration services and marketing agencies or hosts of the systems that deliver the Websites functionalities;
professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services;
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances;
advertisers and advertising networks such as Google and Facebook that require the data to select and serve relevant adverts to you and others. We do not disclose Identity Information about users to our advertisers, but we may provide them with aggregated information or anonymised data about our users. We may also use such aggregated information or anonymised data to help advertisers reach the kind of audience they want to target. We may make use of personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience;
search engine providers such as Google that assist us in the improvement and optimisation of the Website;
bank and payment systems that process bank wires between you and us;
Shopify to power our online store (Website) - you can read more about how Shopify uses your personal data here: https://www.shopify.com/legal/privacy;
Judge.me is our product review partner. Such processing is in accordance with their privacy policy which you agree to when purchasing from our Website. If you wish to unsubscribe from review emails, you will need to do so directly through the link in the Judge.me emails;
others platforms for creating websites that were engaged by us for support and/or creating Website.

11. COOKIE POLICY

Our Website uses cookies. A cookie is a small text file which is stored on your computer, tablet or phone when you visit the Website. These cookies allow us to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our Website.

There are two main types of cookie:

session cookies—these are temporary files, deleted when you finish browsing a website and are not stored on your computer longer than this. The next time you visit that website, the website will not recognise you.
persistent cookies—these are stored on your computer after you have finished using a website so that the website provider can remember your actions and preferences the next time you use it.

Cookies can be set by the website you have browsed, i.e. the website displayed in the uniform resource locator (URL) window. These are called first party cookies. Third party cookies are set by a website other than the one you are browsing.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Website may become inaccessible or not function properly.

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

How do we use cookies?

to estimate our audience size and usage pattern;
to store information about your preferences, and so allow us to customise our site according to your individual interests;
to speed up your searches; and
to recognise you when you return to our site.

Consent

If you continue to use our Website we will assume that you are happy to receive all cookies from our Website. However, if you would prefer to change your cookie settings, you can do so at any time—see below ‘Controlling our use of cookies’.

Controlling our use of cookies

Most browsers automatically accept cookies unless you change your internet browser settings. If you wish to restrict, block or delete the cookies which are set by any websites, you can generally do this through your browser settings. These settings are usually found in the ‘options’ or ‘preferences’ menu of your internet browser.

If you set your internet browser preferences to block all cookies, you may not be able to access all or parts of our Website.

If you delete cookies relating to our Website we will not remember things about you, including your cookie preferences, and you will be treated as a first-time visitor the next time you visit the site.

If you have any questions or comments regarding our Cookies Policy, please contact us.