LONGRICH PRIVACY POLICY

This is the privacy notice of Longrich International (UK) Limited (‘us’, ‘we’, ‘our’), company number 11058419, registered in England and Wales.
Our registered address is 1 Wolston Meadow, Middleton, Milton Keynes, Buckinghamshire, England, MK10 9AY.
Introduction
The purpose of this privacy notice is to inform you about how we process information about you, including information that could identify you (‘personal information’) and information that does not.
If you buy our products from a member of our membership network, this policy also applies to the processing of your personal information by that member. Our members are required contractually to abide by the same rules as we follow.
The relevant law that applies, and with which we comply, is the Data Protection Act 2018 (Act) accordingly incorporating the EU General Data Protection Regulation (GDPR).
In the context of the law and this notice, ‘process’ means collect, store, transfer, use or otherwise act on information.
One of the requirements of the law is to make you aware of your rights and our obligations to you in regard to the processing and control of your personal information. We do this now, by requesting that you read the information provided at http://www.knowyourprivacyrights.org
Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.
If you have any question regarding our privacy policy, please contact us.

1.	Information we process
We may collect, use, store and transfer different kinds of personal information about you depending on our relationship with you.
We categorise these as follows:
‘Customer Information’ is information that you provide to us when you purchase our products. It includes your name, your postal address, your email address, your telephone numbers, your payment information (information about your debit or credit card) and any other information that may identify you as a customer.
‘Member Information’ is information that you provide to us when you join our membership network. It includes your name, your postal address, your email address, your telephone numbers, financial information (information about your bank account and/or about one or more of your debit or credit cards) required for us to transfer commission to you and any other information that may identify you as a member.
‘Communication Information’ is any information that you have provided to us for the purpose of communicating, for any reason.
‘Technical Information’ includes your Internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
‘Marketing Information’ includes your preferences in receiving marketing from us; communication preferences; responses and actions in relation to your use of our website.

2.	Aggregated data
Aggregating is the process of grouping data together.
We may aggregate data such as statistical or demographic data for any purpose. For example, we may assess the popularity of particular pages on our website by using Technical Information to calculate the proportion of visitors who acted in a particular way.
Although aggregated data may be derived from your personal information, it is not considered personal information in law because in aggregating it, it has been anonymised it so that it can no longer be associated with any individual person. It therefore is outside the scope of the Data Protection Act.
However, if we combine or connect aggregated data with your personal information so that it can identify you in any way, we treat the combined data as personal information and it will be used in accordance with this privacy notice.

3.	Special personal information
Special personal information is data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.
We do not knowingly collect any special personal information about you.
The bases on which we process information about you
The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.
If a basis on which we process your personal information becomes no longer relevant then we shall immediately stop processing your information.
If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

4.	Contractual obligation
When you buy a product from us or from one of our members, when you join our network as a member, or otherwise agree to our terms and conditions, a contract is formed between you and us.
In order to carry out our obligations under that contract we must process the information you give us. This information is likely to be personal information such as Customer Information or Member Information.
We may use it in order to:
•	fulfil an order for products
•	provide you with the benefits of membership
•	provide you with personalised suggestions and advice
We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
If you fail to provide personal information to us, or no longer consent to our use of it, then we may not be able to perform our contract. If so, we shall notify you at the time.

5.	Consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, our network or our products, you provide your consent to us to process information that may be personal information.
For example, this information may be Technical Information or Marketing Information.
Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies.
However, through some of your actions, we might reasonably assume that you give your implicit consent to our processing of personal information.
Only in situations where you have given us explicit permission to do so, do we pass your name and contact information to anyone outside our network or business.
We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us online through the contact page of our website or in writing to our registered office address.

6.	Legitimate interests
We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.
Where we process your information on this basis, we do after having given careful consideration to:
•	whether the same objective could be achieved through other means
•	whether processing (or not processing) might cause you harm
•	whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so
For example, we may process any category of personal information on this basis for the purposes of:
•	the necessary administration of our business
•	responding to unsolicited communication from you to which we believe you would expect a response
•	protecting and asserting the legal rights of any party, including your interests where we believe we have a duty to do so
•	insuring against or obtaining professional advice that is required to manage business risk

7.	Legal obligation
Sometimes, we must process your information in order to comply with a statutory legal obligation.
For example, we may be required to give information to the police or to a government department if they have the power to request that information or the proper authorisation, such as a search warrant or court order.
This may include your personal information.
Specific uses of information you provide to us

8.	Communicating with us
When you contact us, whether by telephone, through our website or by e-mail, we process the information you have given us in order to reply to you. This information is likely to include personal information such as your name and your address, your email address or your telephone number.
We record all communication with you in order to be able to refer to it at a later date if necessary and provide you with a high level of service.
If you request that we do so, we may pass some of the information contained in your message to one of our members or someone outside of our organisation.

9.	Payment information and financial information
Except where we expect that you will make multiple purchases and where you agree to our holding of your payment information, when we take payment from you as a customer, we collect your payment information for the purpose of a single transaction only. We do not store information about your debit or credit card for longer than required for the transaction.
If you join our membership network, you may request that we keep your financial information so that you can more easily pay your subscription as it falls due and so that we can pay commission on sales to you. We shall notify you when you provide your financial information how we shall use it.
To assist in combating fraud, we may share information with credit reference agencies.

10.	Job application and employment
If you send us information in connection with a job application, we keep it only for as long as reasonably required by us.
If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for no longer than six years before destroying or deleting it.

11.	Cookies
Our cookie notice tells you about how we use cookies on our website.

12.	Personal identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the web pages on our website and how we perform in providing content to you.
Other matters

13.	Data may be processed outside the European Union
From time to time, personal information obtained within the UK or any other country could be processed outside the European Union.
Where this occurs, we use one of the following safeguards:
•	either the processor is within the same corporate group as our business or organisation and abides by the same binding corporate rules regarding data processing; or
•	we have a contract with the data processor that includes transfer clauses that oblige the data processor to process the data to the same standards as to which we are obliged.

14.	Control over your own information
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes.
At any time you may contact us to request that we provide you with the personal information we hold about you.
When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
Please be aware that we are not obliged by law to provide you with all personal information we hold about you, and that if we do provide you with information, the law allows us to charge for such provision if doing so incurs costs for us. After receiving your request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.
Likewise, we are not obliged by law to delete your personal information or to stop processing it simply because you do not consent to us doing so. While having your consent is an important consideration as to whether to process it, if there is another legitimate basis on which we may process it, we may do so on that basis.

15.	Use of our website by children
We do not sell products or provide services for purchase by children, nor do we market to children.
However, we collect information about all users of and visitors regardless of age.

16.	Encryption of data sent between us
We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.
Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

17.	Complaining
If you are not happy with our privacy policy, or if you have any complaint, then you should tell us.
When we receive a complaint, we record all the information you have given to us on the basis of consent. We use that information to resolve your complaint.
If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner's Office (ICO). This can be done at https://ico.org.uk/make-a-complaint/. We would, however, appreciate the opportunity to talk to you about your concern before you approach the ICO.

18.	 Retention period
Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:
•	to provide you with the products and services you have requested
•	to comply with other law, including for the period demanded by our tax authorities
•	to support a claim or defence in court

19.	Compliance with the law
Our privacy policy has been compiled so as to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you.

20.	Review of this privacy policy
We may update this privacy notice from time to time as necessary.