This Privacy Policy explains which personal data Leading Commerce LTD processes when you visit this website, contact us or buy a product, why we process it, who receives it and which rights you have.
1. Who is responsible for your data
Leading Commerce LTD is the controller of the personal data described in this policy.
- Company: Leading Commerce LTD, registered in England and Wales, company number 17503044
- Registered office: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom
- Email for all data protection matters: contact@leadingcommercegroup.com
We process personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 and, where we offer our products to people in the European Union, the EU General Data Protection Regulation (EU GDPR).
2. The personal data we process
We process only the data that is needed to run this website, to answer enquiries and to fulfil orders.
- Enquiries. When you write to us by email, including through the contact form, we receive your name, your email address, the subject, your message and, if you provide it, your order number. By default the contact form opens your own email application; nothing you type into the form is sent to or stored on the server of this website. Your enquiry reaches us as a normal email.
- Order data. When you buy a product, the details needed for the order are collected on the checkout page, such as your name, your email address, the product bought, the price, the date and time of the order, the order number, the payment status and any billing details requested at checkout. We receive this order data from the checkout. We do not receive or store complete card numbers; payment details are handled by the payment service provider.
- Technical data. When you open a page, the servers of our hosting provider process the technical data that your browser sends, such as your IP address, the date and time of the request, the page requested, the referring page and the type of browser and operating system, and may record it in server log files.
- Cookie and language preferences. Your choice about analytics, with its date and the version of the notice, and the language you selected are saved in the local storage of your browser under the names lc_consent and lc_lang. These entries stay on your device.
- Analytics data. Analytics tools are not active on this website at present. If we enable them in future, they will be loaded only with your consent and will then collect information about how the website is used.
We do not ask for special categories of personal data, such as data concerning health. Please do not include such information in your messages to us.
You are not obliged to give us personal data. Without the details requested at checkout, however, an order cannot be processed, and without an email address we cannot reply to you or send access instructions.
We do not use personal data for automated decision-making, including profiling, that has legal or similarly significant effects on you.
3. Purposes and lawful bases
We process personal data only where the law allows it. The lawful bases below refer to Article 6(1) of the UK GDPR and of the EU GDPR.
- Processing your order, providing access to the product and handling withdrawals and refunds: performance of a contract with you (Article 6(1)(b)).
- Answering enquiries and providing support: performance of a contract or steps taken at your request before a contract is concluded (Article 6(1)(b)) where your enquiry relates to an order; otherwise our legitimate interest in answering people who contact us (Article 6(1)(f)).
- Keeping accounting and tax records and meeting other legal duties: compliance with a legal obligation (Article 6(1)(c)).
- Delivering the website, keeping it secure and detecting and preventing misuse and fraud: our legitimate interest in a secure and reliable website (Article 6(1)(f)).
- Saving your cookie choice and your language: our legitimate interest in recording your choice and showing the website in your language (Article 6(1)(f)). These entries are strictly necessary within the meaning of the rules on cookies and similar technologies.
- Establishing, exercising or defending legal claims: our legitimate interest in protecting our legal position (Article 6(1)(f)).
- Analytics, if enabled in future: your consent (Article 6(1)(a)), which you can withdraw at any time.
4. Who receives your data
We pass personal data on only where this is needed to run the website and to fulfil orders, or where the law requires it. The recipients are:
- Our hosting provider, which delivers the pages of this website and processes the technical data described above on our behalf.
- Checkout and payment. The checkout page is operated for us on our own checkout subdomain, and payments are processed by our payment service provider. The payment service provider receives the payment details you enter and also processes them under its own legal obligations, for example to prevent fraud.
- Providers of email and product delivery services, which we use to receive and answer your messages, to send order confirmations and access instructions and, where a product includes one, to provide the member area.
- Analytics providers, only if analytics is enabled in future and only with your consent.
- Professional advisers, such as accountants and lawyers, and public authorities, such as tax authorities, where this is necessary to meet a legal obligation or to establish, exercise or defend legal claims.
We do not sell your personal data, and we do not pass it on to third parties for their own advertising.
5. International transfers
We are established in the United Kingdom. If you live in the European Union, your personal data is therefore processed in the United Kingdom. Transfers from the European Union to the United Kingdom are covered by the European Commission’s adequacy decisions for the United Kingdom for as long as these remain in force.
Some of our service providers may process personal data in countries outside the United Kingdom and the European Economic Area. Where this happens, we rely on an adequacy decision or on appropriate safeguards, such as the standard contractual clauses approved by the European Commission and the UK International Data Transfer Agreement or Addendum.
You can ask us for information about the safeguards used for a transfer by writing to contact@leadingcommercegroup.com.
6. How long we keep your data
We keep personal data only for as long as it is needed for the purposes described in this policy or for as long as the law requires. After that we delete or anonymise it.
- Enquiries: for as long as is needed to deal with your request and for up to two years after our last message to you, unless the enquiry belongs to an order.
- Order data, invoices and records of refunds and withdrawals: for six years after the end of the financial year to which they relate, as required for accounting and tax purposes.
- Technical data in server log files: for the limited period set by our hosting provider for security and troubleshooting, after which it is deleted or anonymised.
- Cookie and language preferences: these stay in your browser until you change them or clear the site data in your browser.
- Data needed for legal claims: until the claim has been settled and the applicable limitation period has expired.
- Analytics data: none at present. Should analytics be enabled, the retention period will be stated here before it starts.
7. Your rights
Under the UK GDPR and the EU GDPR you have the following rights in relation to your personal data:
- Access: to be told whether we process your personal data and to receive a copy of it.
- Rectification: to have inaccurate data corrected and incomplete data completed.
- Erasure: to have your data deleted where there is no longer a lawful reason for us to keep it.
- Restriction: to have the processing of your data restricted in certain cases, for example while its accuracy is being checked.
- Data portability: to receive data that you provided to us, and that we process by automated means on the basis of a contract or your consent, in a structured, commonly used and machine-readable format, or to have it sent to another controller.
- Objection: to object at any time, on grounds relating to your particular situation, to processing that is based on our legitimate interests, and to object at any time to the use of your data for direct marketing.
- Withdrawal of consent: to withdraw at any time a consent you have given. This does not affect the lawfulness of processing carried out before the withdrawal.
Some of these rights apply only in certain circumstances. If we cannot comply with a request, we will tell you why.
8. How to exercise your rights
To exercise any of these rights, write to contact@leadingcommercegroup.com. Exercising your rights is free of charge.
We may ask you for information that we need to confirm your identity, so that personal data is not disclosed to the wrong person.
We will reply within one month of receiving your request, as the law requires. For complex or numerous requests the law allows this period to be extended by up to two further months; if we need the extension, we will tell you within the first month.
You can change your cookie choice at any time through the “Cookie settings” link in the footer of every page.
9. Your right to complain
If you believe that we have not handled your personal data correctly, please write to contact@leadingcommercegroup.com so that we can look into it.
You also have the right to lodge a complaint with a supervisory authority. In the United Kingdom this is the Information Commissioner’s Office (ICO), ico.org.uk. If you live in the European Union or the European Economic Area, you can contact the data protection authority of the country in which you live or work or in which you believe the infringement took place.
10. Children
This website and our products are intended for adults. Some materials are designed for adults to use with children, for example parents and teachers, but we do not sell to children and do not knowingly collect personal data from anyone under 18.
If you believe that a child has given us personal data, please write to contact@leadingcommercegroup.com and we will delete it.
11. Security
We use appropriate technical and organisational measures to protect personal data against loss, misuse and unauthorised access. The website is delivered over an encrypted connection (HTTPS). It consists of static pages and does not itself store customer accounts, order data or payment data. We limit access to personal data to the people who need it for their work.
No transmission over the internet is completely secure. If you have reason to believe that your data is at risk, for example because login details have become known to someone else, please tell us at once at contact@leadingcommercegroup.com.
12. Cookies, local storage and other services
This website sets no cookies of its own and makes no requests to third-party servers; the fonts are hosted on our own server. It uses the local storage of your browser for two strictly necessary entries. Details are set out in our Cookie Policy.
The checkout page and the member areas are separate services. When you use them, your data is processed as described in this policy; the payment service provider’s own privacy information also applies to the payment.
13. Changes to this policy
We may update this policy, for example when we change the way the website works or use a new service provider. The date of the latest update is shown at the top of this page. If we name a payment service provider or enable analytics, this policy will be updated before the change takes effect.