This notice sets out how INXX. processes your personal data if you are a customer or a user of INXX.'s website or mobile applications. INXX.'s services are neither aimed at nor intended for children. If you are a child, then you must inform your parent or guardian of this notice.
INXX. is the trading name of MOSTLY SUNNY PROPERTIES LLC (collectively referred to as "INXX.", "we", "us" or "our" in this notice). We are the data controller of your personal data.
Our data protection officer (DPO) is responsible for overseeing questions in relation to this notice. If you have any questions about this notice, including any requests to exercise your legal rights, then please contact our DPO at firstname.lastname@example.org.
We may update this notice from time to time and will notify you of changes where we are required to do so by law.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. An easy way to do this is through your INXX. account, but please also feel free to contact us.
Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store, transfer and otherwise process different kinds of personal data about you which we have grouped together as follows:
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (e.g., to provide you with products/services). In this case, we may have to cancel a product/service but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including as set out below:
We will only process your personal data when the law allows us to do so. Most commonly, we will process your personal data in the following circumstances:
With limited exceptions (e.g., some of our electronic marketing), we do not rely on consent as a lawful basis for processing your personal data. You have the right to withdraw consent to marketing at any time by contacting us.
We have set out below a description of all the ways we plan to process your personal data, and which of the lawful bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Purpose/Activity: To register you as a new customer
Purpose/Activity: To process and deliver your order (including managing payments, fees and charges, and collecting and recovering money owed to us)
Purpose/Activity: To manage our relationship with you (including notifying you about changes to our terms or this notice and asking you to leave a review or take a survey)
Purpose/Activity: To enable you to take part in a prize draw, competition, raffle or complete a survey
Purpose/Activity: To administer and protect our business, website and mobile applications (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Purpose/Activity: To deliver relevant content and advertisements to you and measure or understand the effectiveness our advertising
Purpose/Activity: To use data analytics to improve our website, mobile applications, products/services, marketing, customer relationships and experiences
Purpose/Activity: To make suggestions and recommendations to you about products/services that may be of interest to you
Purpose/Activity: To keep our stores safe and secure
We will only process your personal data for the purposes that we collected it, unless we reasonably consider that any further processing is compatible with the original purpose. If you would like an explanation as to how further processing is compatible with the original purpose, then please contact us.
If we need to process your personal data for an unrelated purpose, then we will notify you and we will explain the lawful basis which allows us to do so.
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.
You will receive marketing communications from us if you have requested information from us or purchased products/services from us and you have not opted out of receiving that marketing.
If you ask us to stop processing your personal data for marketing purposes (e.g., by following the opt-out links on any electronic marketing sent to you or by otherwise contacting us), then we will do so.
We do not share your personal data with any third parties for their own marketing purposes.
We may have to share your personal data with the parties set out below for the purposes that we collected the personal data.
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 process 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.
In some cases the parties who we use to process personal data on our behalf are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
If you would like further information on the specific mechanism used by us when transferring your personal data out of the EEA, then please contact us.
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.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements and for the establishment or defence of legal claims.
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.
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.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. In summary these are the rights of access, rectification (i.e., correction), erasure (also known as the "right to be forgotten"), restriction, objection, data portability and withdrawal of consent. If you wish to exercise any of these rights, then please contact us.
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 could refuse to comply with your request in these circumstances.
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.
We try to respond to all legitimate requests within one month. Occasionally it could 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.
You also have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please feel free to contact us in the first instance.