Privacy Policy

Last updated: 1st March 2019

This privacy policy (the "Privacy Policy") governs the manner in which LTOYS, a Luxembourgish limited liability company (société à responsabilité limitée) with registered office at 141, route de Trèves, L - 6940 Niederanven, GRAND DUCHY OF LUXEMBOURG, registered with the Luxembourg Trade and Companies Registry under number B 220946 or any of its affiliated companies ("LTOYS") collects, uses, maintains and discloses information collected from clients and/or users (each, a "User" or "Users") of its websites, physical stores, mobile applications or any other services (the "Services").

Compliance with Data protection Law

LTOYS acknowledges and undertakes to comply with the laws and regulations governing the processing of personal data, including, but not limited to, the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC ("GDPR") and any other national applicable laws or regulations governing the processing of personal data in the framework of the Services.

Data protection officer

LTOYS acts as data controller and has appointed a data protection officer.

The data protection officer appointed by LTOYS shall be contacted by using the following information:

Send e-mail to : support[at]ltoys.lu

Personal data

LTOYS may collect personal data from Users in a variety of ways, including, but not limited to, when Users visit LTOYS' websites, register on such websites, fill out a form, sign a contract, purchase a product, use applications and, in general, benefit from Services proposed by LTOYS. Users may be asked for, as appropriate, personal identifying information (name, date of birth, email address, mailing address, phone number, etc.) and bank identification data (means of payment used in exchange for the Services).

Non-personal data

LTOYS may collect non-personal data about Users whenever they use an LTOYS website or application or other online service. Non-personal data may include technical information about Users means of connection, such as the operating system and the Internet service provider utilized, behavioural information such as time spent on site, as well as further non-personal analytical data to improve customer experience, products and services.

Each User recognizes and accepts that the performance of the Services may depend on the collection and processing of personal data and non-personal data.

Web browser cookies

LTOYS may use « cookies » to improve the User's experience in regard of the Services. In that case, the User's Internet navigator places cookies on his hard drive to gather a certain set of information used to customize the navigation in the framework of the Services, thus enabling certain unique functionalities. All information related to the cookies policy are available on [insert URL].

How LTOYS uses collected information

Principally, personal and non-personal data is used to provide the Users with the Services and to insure a full efficiency of the Services they have registered for or they requested in any other manner.

In this framework, LTOYS may collect and use Users' personal and non-personal data for the following purposes:

• To provide the Services: the information provided by Users is required to provide the Services.
• To personalize User experience: LTOYS may use non-personal data to understand how Users as a group use LTOYS' services.
• To improve Services: Information Users provided will help LTOYS to respond to certain Users' requests.
• To improve LTOYS' websites and other internet presence as well as other communication tools or tools for specific Services: LTOYS may use feedback that Users provide to improve its products and services. This information is processed on the basis of LTOYS\' legitimate interests. There is no risk to the rights and freedoms of Users, as this information only concerns Users\' opinions on the Services offered by LTOYS and is provided at the sole discretion of Users.
• To send periodic letters and other text messages and/or notifications, by post or telephonically and to respond to inquiries, questions, and/or other requests: LTOYS may use the email, postal address or mobile phone number provided by Users who accepted it. If Users accepts to be on LTOYS notification list, they will receive periodic information that may include news, updates, related product or service information, private sales, promotional offers, information from LTOYS or its service providers etc. (the "Periodic Information Service"). The sending of Periodic Information is in LTOYS\' legitimate interests as long as the applicable provisions on the protection of privacy in the electronic communications sector are respected. Periodic Information is sent by post and telephone with the User\'s consent.

How LTOYS protects personal data

LTOYS adopts appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of Users' personal data within the limits of LTOYS' role with respect to the relevant Services (as certain specific services might be rendered by third parties).

Sharing personal information

LTOYS does not sell, trade, or otherwise transfer to third parties Users' personal data. However, the User personal data can be transmitted to website hosting and editing partners and other sub-contractors who assist LTOYS in providing the Services, conducting its business, or servicing the User, so long as those sub-contractors undertake to process the information only according to LTOYS instructions and to comply with the applicable law regarding the protection of personal data. LTOYS may also release User's personal data when it believes that such release is necessary to comply with the law, enforce its websites' general terms of use, or protect its or others\' rights, property, or safety.

However, Users non-personal data may be provided to third parties for marketing, advertising, or other uses.

Changes to this Privacy Policy

LTOYS has the discretion to update this Privacy Policy at any time. Where appropriate, LTOYS will revise the "last update date" at the bottom of this page. LTOYS encourages Users to frequently check this page for any changes. Users acknowledge and agree that it is their responsibility to review this Privacy Policy periodically and become aware of modifications.

Data Retention

LTOYS takes all reasonable measures to ensure that User' personal data are processed for the minimum period necessary for the purposes set out in this Privacy Policy. The Personal Data will be retained by LTOYS according to the following criteria:

• as long as LTOYS maintain an ongoing relationship with the User (e.g., where the User is a recipient of LTOYS' Services, or is lawfully included in LTOYS' mailing list and has not unsubscribed);
• as long as the User' personal data are necessary in connection with the purposes set out in this Privacy Policy, for which LTOYS has a valid legal basis
• until the expiry of a period of two (2) months following the end of any applicable limitation period under applicable law; and
• with the User' prior consent, until the expiry of any additional retention period.

LTOYS undertakes to delete or to anonymise the User' personal data upon expiry of the retention period as described above.

Data Security and data transfer

LTOYS has implemented appropriate technical and organizational security measures designed to protect the User personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of processing, in accordance with applicable law.

The User is responsible for ensuring that any personal data that he/she send to us are sent securely.

LTOYS does not transfer personal data to any third country nor to any international organisation, except as the case may be on the basis of:

• adequacy decisions;
• suitable Standard Contractual Clauses; or
• other valid transfer mechanisms under GDPR.

Data Accuracy and minimization

We take reasonable measures:

• to ensure that the User' personal data are accurate and, where necessary, kept up to date and accurate; and
• that the User' personal data are collected on an as needed basis in connection with the purposes set out in this Privacy Policy.

Data subject rights

The User has a right to withdraw his/her consent or to oppose to the processing of his/her personal data concerning the Periodic Information at any time. Such withdrawal won't affect the lawfulness of the processing based on consent before such withdrawal nor of the processing based on another legal basis within the meaning of the GDPR. For the case that, at any time, Users would like to unsubscribe from Periodic Information, LTOYS includes detailed unsubscribe instructions at the bottom of each such email or other text message and each User may oppose such processing by contacting the DPO at the contact details mentioned above.

Each User benefits under data protection law from a right of access, modification and opposition to the processing of its personal data, a right to erasure and a right to portability of its personal data by sending an email to [LTOYS's e-mail address].Those rights may only be exercised within the limits of any contractual or legal obligation and under the conditions set out in the GDPR. Each User has also a right to lodge a complaint with the Luxembourg supervisory authority, namely the Commission nationale pour la protection des données (https://cnpd.public.lu/fr.html).

Acceptance of these terms

By using the Services, Users confirm their acceptance of this Privacy Policy. If a User does not agree with this Privacy Policy, LTOYS recommends to such User that he shall not use the Services. The continued use of the Services following the posting of changes to this Privacy Policy will be deemed as an acceptance of those changes.