PRIVACY POLICY
We are committed to protecting your privacy. In this Privacy and Cookies Policy for our Sites, and the services, features, content or applications we offer, including our Content (defined below) (collectively with the Sites, the "Services"). We explain who we are, why and how we collect, store, share and use (together, "process") personal data ("Personal Information"), as well as your rights and how to contact us.
We work across our Sites, our social media channels and/or other third party platforms to whom we licence content (referred to together in this policy as the “LUXE VARIE”). We collect, receive, record, produce, store, publish and otherwise use or disseminate editorial, journalistic and/or commercial content (collectively, "Content"). As part of our media business, we may gather and/or receive information from a wide variety of sources (including without limitation from people, companies, organisations, events, meetings, public records, the Internet, filming, audio-recording, photography and social and other media, and other published content or documents). We may publish, disseminate, make available and/or share Content via the Luxe Varié ("Publishing" or "Published Content"). Publishing is carried out in multiple ways (including via online articles, video, audio-visual pieces, photographs, newsletters, archives and social media) and about diverse topics. Content may sometimes include Personal Information. Not all Content we process is Published.
Please read this policy carefully to understand our views and practices regarding your personal information and how we will treat it. By engaging with our Services, you acknowledge you have read and understood this privacy policy.
We are the data controller of the personal information processed in relation to this policy, except where this policy explains otherwise. This means we are responsible for treating your personal information safely, in accordance with applicable data protection and privacy laws. If you have any questions about how we protect your Personal Information, please contact us.
WHAT DOES THIS PRIVACY POLICY COVER?
This Privacy Policy covers how we treat
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Personal Information gathered when you are using or accessing our Services.
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Personal Information that our business partners share with us or that we share with our business partners.
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Personal Information in any Content.
Our Services may, from time to time, contain links to external websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies.
THIRD PARTY SERVICES
This Privacy Policy does not apply to the practices of third parties that we do not own or control, including but not limited to: any third party websites, services and applications and any affiliated brands (“Third Party Services”) that you elect to access through the Service or to individuals that we do not manage or employ. We do not have any responsibility or liability for these policies or any content on Third Party Services and do not necessarily endorse the views expressed within them. We have no control over the availability of any of those Third Party Services. We encourage you to carefully review the privacy policies of any Third Party Services you access. Please refer to Information You Elect to Share for further information.
WHAT INFORMATION DO WE COLLECT?
We process information about you in the following contexts:
Category: Sign-up Information
Context
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When you sign up to one of our newsletters, you will provide us with your email address. If you sign-up by providing your email address through Facebook, we will get your email address from Facebook. That's it, we don't ask for anything extra.
Primary Purpose for Collection and Use of Data
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We share newsletters with individuals who consent to receive such communications. We also have a legitimate interest in sharing information about our Sites.
Category: Competition, Digital Events, and other Giveaways Information
Context
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If you enter one of our competitions, sign up for one of our digital events, or participate in other giveaways, you agree to the relevant competition or event terms, and may provide us with your first and last name, age, email address, postal code and any further information listed in the relevant sign up form. You may also need to provide us with further information to verify your identity if you win.
Primary Purpose for Collection and Use of Data
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We have a legitimate interest in operating competitions and digital events. In some contexts, we are also required by law to collect information about those that enter our competitions, and we have a legitimate interest in complying with those laws.
Category: Contact Information
Context
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If you email us, you provide us with your email address, and any other information you choose to provide (for example, your name or information in your email signature).
Primary Purpose for Collection and Use of Data
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We have a legitimate interest in communicating with you about our Sites.
Category: Social Media Information
Context
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If you follow us on another website or platform, we generally do not get any Personal Information about you from them.
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However, if you engage with us on another website or platform, for example by leaving a comment on our page, we can view these comments via that relevant website or platform. Similarly, if you message us directly on another website or platform, we will have access to the Personal Information you have chosen to provide to us via that relevant website or platform (for example, if you send us a picture) – we don't, however, copy or store that information anywhere else.
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Please refer to the relevant other website or platform's terms & conditions and privacy policy.
Primary Purpose for Collection and Use of Data
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We have a legitimate interest in reviewing comments left on our social media pages, and in responding to messages we receive on social platforms.
Category: Technical Information about Your Visit
Context
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We use this for marketing and advertising analysis, including providing more relevant advertising on our Sites.
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We may also receive a confirmation when you open and engage with an email from us.
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Technical information may include the partial Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
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Information about your visit may include the full Uniform Resource Locators (URL), clickstream to, through and from our Platform (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and potentially any social media handle used to connect with our team. While we collect and store IP address information, this information is not made public and is pseudonymised.
Primary Purpose for Collection and Use of Data
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We have a legitimate interest in understanding how you interact with our website to better improve it, and to understand your preferences and interests in order to select offerings that you might find most useful. We also have a legitimate interest in detecting and preventing fraud. We also have a legitimate interest in monitoring our networks and the visitors to our websites. Among other things, it helps us understand which of our services is the most popular.
Category: Content
Context
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As part of our editorial, journalistic and/or commercial activities in relation to Content, we may receive, collect, store, analyse, Publish, use and otherwise disseminate or process (in any media) personal data for the purposes of and/or in connection with our Publishing activities.
Primary Purpose for Collection and Use of Data
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As a media company that publishes editorial content, we have a legitimate interest in Publishing content that may include personal information.
Category: Recordings
Context
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As part of the process of receiving, gathering, producing and/or creating Content, we may conduct filming (including audio and video recording and photography) in a studio or other private location, and/or in public places.
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Our recording will include you if you have agreed to be in or provide Content, and may also include you when we are filming in places and you have entered the area.
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In some cases, we may enter into contracts and/or releases with individual or corporate sources or providers of information or those who give us access to locations or information or with whom with have commercial or editorial partnerships. Such contracts and/or releases may be for editorial and/or commercial purposes. Where these apply, they will generally explain how we use any relevant data.
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We may record your likeness, including your name, image, biography, résumé, voice, sounds, actions or performances.
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When filming Content in public places, we will generally post Filming Notices around the area to let you know that filming is occurring, and that if you enter the area that you may be photographed and recorded and your likeness may appear in our Content without credit or compensation. Where our journalists are filming in public and at live events, we may not be using Filming Notices. If you do not wish to be filmed, photographed or recorded, you should not enter any area in which filming is happening – if you do so it is your responsibility to inform our journalist(s) or other Bustle staff onsite & involved in the filming], but it may not be possible to entirely exclude your image and/or voice from the Content, despite any request made.
Primary Purpose for Collection and Use of Data
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We have a legitimate interest in making recordings as a part of our content-generating process. In some circumstances, this collection may also be based upon consent.
Category: Information Provided When Submitting Content
Context
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We may from time to time ask you (and our readers generally) to submit your own text, video and/or audio recordings and/or photography to us. If you respond to one of our submission requests, you'll be providing us with the contact details from which you make your submission (e.g. email address or online handle), and any additional information you provide alongside it (for example, extra information about a video). Where you provide information to us for media purposes, including by communicating with one of our editorial team or providing them with information (including by making your information available), you acknowledge that we may process this information including with a view to Publication. If you have any concerns about confidentiality when responding to one of our submission requests, please email us at info@luxevarie.com Please read the rest of this policy carefully, including in particular the information about How Is My Information Used? and How long we keep your information.
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We may receive video and/or audio recordings or photography which other individuals submit to us, for example videos of public events.
Primary Purpose for Collection and Use of Data
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We process this information based upon your consent.
Category: Email Interconnectivity
Context
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If you receive email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases.
Primary Purpose for Collection and Use of Data
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We have a legitimate interest in understanding how you interact with our communications to you.
Category: Feedback/Support
Context
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If you provide us feedback or contact us for support we will collect your name and e-mail address, as well as any other content that you send to us, in order to reply.
Primary Purpose for Collection and Use of Data
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We have a legitimate interest in receiving, and acting upon, your feedback or issues.
Category: Mobile Devices
Context
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We collect information from your mobile device such as unique identifying information broadcast from your device when visiting our website.
Primary Purpose for Collection and Use of Data
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We have a legitimate interest in identifying unique visitors, and in understanding how users interact with us on their mobile devices.
Category: Partner Promotions
Context
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We collect information that you provide as part of a co-branded promotion with another company.
Primary Purpose for Collection and Use of Data
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We have a legitimate interest in fulfilling our promotions.
Category: Applicants
Context
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If you apply for a job, we may collect your name and contact information, along with a copy of your resume, work history or work authorization information.
Primary Purpose for Collection and Use of Data
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We have a legitimate interest in reviewing candidates for potential jobs.
Category: Independent Contractors
Context
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We collect information from you if you work for us as an independent contractor, or if we contract with you for services. We may collect your name, address, email address, social security number, bank account information, and demographic information.
Primary Purpose for Collection and Use of Data
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We have a legitimate interest in utilizing independent contractors to perform services. We also collect this information to fulfil our contracts with independent contractors.
Category: Surveys
Context
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When you participate in a survey we collect information that you provide through the survey. If the survey is provided by a third party service provider, the third party’s privacy policy applies to the collection, use, and disclosure of your information.
Primary Purpose for Collection and Use of Data
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We have a legitimate interest in understanding your opinions, and collecting information relevant to our organization.
Category: Location Data
Context
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We collect information through the Sites as to your real time location to provide location services where requested or agreed to by you in order to deliver content, advertising or other services that are dependent on knowing where you are.
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Delivery of location services will involve reference to one or more of the following: (a) the coordinates (latitude/longitude) of your location; (b) look-up of your country of location by reference to your IP address against public sources; and/or (c) potentially your Identifier for Advertisers (IFA) code for your Apple device, or the Android ID for your Android device, or a similar device identifier.
Primary Purpose for Collection and Use of Data
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We have a legitimate interest in understanding our users and providing tailored services. In some contexts our use is also based upon your consent to provide us with geo location information.
Category: Cookies and first party tracking
Context
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We use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a web site is viewed. This information can be used to identify your IP address. See our Cookie Policy for more information.
Primary Purpose for Collection and Use of Data
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We have a legitimate interest in making our website operate efficiently.
Category: Cookies and Third Party Tracking
Context
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We participate in behavior-based advertising, this means that a third party uses technology (e.g., a cookie) to collect information about your use of our website so that they can provide advertising about products and services tailored to your interests on our website, or on other websites. See our Cookie Policy for more information.
Primary Purpose for Collection and Use of Data
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We have a legitimate interest in engaging in behavior-based advertising and capturing website analytics.
We may also use the above information for internal administrative purposes.
In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources.
WHO IS MY INFORMATION SHARED WITH?
INFORMATION SHARED WITH OUR SERVICE PROVIDERS:
We employ and contract with people and other entities that perform certain tasks on our behalf (our “service providers”).
We may share Personal Information with our service providers in order to provide our Services to you. Unless we tell you otherwise, our service providers may only use Personal Information we share with them in in accordance with our instructions.
Our service providers include:
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Customer support and engagement software & services
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Cloud storage hosting and providers
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Newsletter and email marketing providers
AGGREGATE INFORMATION
Aggregate information does not include any personal information which you can be identified from. We share aggregate information with our partners, service providers and other persons with whom we conduct business. We share this type of statistical data so that our partners can understand how and how often people use our Services and their services or websites, which facilitates improving both their services and how our Services interface with them.
In addition, these third parties may share with us anonymised, aggregated or otherwise non-personal information about you that they have independently developed or acquired.
CONTENT & RECORDINGS
We may share our Content across Luxe Varié and third party distribution channels. Our Content may be seen globally by our users and viewers, including users of the Internet and/or social media platforms, as well as third parties’ platforms and channels who license or purchase our Content.
We may also disclose your personal information to:
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Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, who support our processing of personal data under this policy (if any of these parties are using your information for direct marketing purposes, we will only transfer the information to them for that purpose with your prior consent); and
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Third-party sites or platforms, such as social networking sites and third party distribution channels.
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Organisations and individuals who are responsible, in whole or in part, for the production and/or distribution of the Content. This includes film crews, producers, editors and others involved in the foregoing.
OTHER DISCLOSURES WE MAY MAKE
We will disclose your personal information to third parties if we buy or sell part of our (or another) business, or if we are required to do so in order to comply with a legal obligation.
INFORMATION DISCLOSED PURSUANT TO BUSINESS TRANSFERS
In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this policy.
INFORMATION DISCLOSED FOR OUR PROTECTION AND THE PROTECTION OF OTHERS
We also reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to (i) satisfy any applicable law, regulation, legal process or governmental request, (ii) enforce the Terms of Service, including investigation of potential violations hereof, (iii) detect, prevent, or otherwise address fraud, security or technical issues, (iv) respond to user support requests (as explained above), or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organisations for fraud protection and to prevent cybercrime, including spam/malware prevention.
INFORMATION SHARED WITH OUR BUSINESS PARTNERS
WE MAY OFFER CONTESTS, SWEEPSTAKES, OR OTHER PROMOTIONS WITH THIRD PARTY PARTNERS. IF YOU DECIDE TO ENTER A CONTEST, SWEEPSTAKES, OR PROMOTION THAT IS SPONSORED BY A THIRD PARTY PARTNER, THE INFORMATION YOU PROVIDE WILL BE SHARED WITH US AND WITH THEM. THEIR USE OF THIS INFORMATION IS NOT GOVERNED BY THIS POLICY.
INFORMATION WE SHARE WITH YOUR CONSENT
We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.
INFORMATION YOU ELECT TO SHARE
You may access other Third Party Services, including other websites and platforms, through the Services for example by clicking on links to those Third Party Services from within the Site. We are not responsible for the privacy policies and/or practices of these Third Party Services, and you are responsible for reading and understanding those Third Party Services’ privacy policies. This Privacy Policy only governs information collected as part of our Services.
PUBLIC INFORMATION ABOUT YOUR ACTIVITY ON THE OTHER WEBSITES OR PLATFORMS
Where you engage with Bustle accounts on other third-party websites or platforms (for example, social media), some of your activity may be public by default. This may include, but is not limited to, content you have posted publicly on those websites or otherwise through the Services, such as written posts, comments, or other submissions by you. Please also remember that if you choose to provide Personal Information using certain public features of other websites or platforms, then that information is governed by the privacy settings of those other websites or platforms and may be publicly available. Individuals reading such information may use or disclose it to other individuals or entities without our control and without your knowledge, and search engines may index that information. We therefore urge you to think carefully about including any specific information you may deem private in content that you submit when engaging with Bustle on other websites or platforms
IS INFORMATION ABOUT ME SECURE?
We store all of our information, including your IP address information, using industry-standard techniques.
Unfortunately, the transmission of information via the internet is not completely secure. We do our best to protect your personal information, but we cannot guarantee or warrant that such techniques will prevent unauthorised access to information about you that we store, Personal Information or otherwise; any transmission is at your own risk. Once we have received your information, we use strict procedures and security features to try to prevent unauthorised access. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
Our original recordings are kept on secure, password, protected servers or networks. However, our Content is posted publicly on the internet. Published Content will made freely available via the internet where it is not subject to additional security measures.
We may operate registration and/or paywalls in relation to Content. Some of those Sites may permit you to create an account. When you do, you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account.
WHERE DO YOU STORE MY INFORMATION?
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA) that may not be subject to equivalent Data Protection Law.
Bustle may also record Content in the EEA, the UK, the US, and in other countries around the world. Your personal information which we record or otherwise receive or collect is sent to and stored on secure servers located in the United States. Such storage is necessary in order to process the information.
Where your information is transferred outside the EEA, we will take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards, such as relying on a recognised legal adequacy mechanism, and that it is treated securely and in accordance with this privacy policy.
We may transfer your personal information outside the EEA, including but not limited to, the following reasons:
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in order to store it.
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in order to enable us to provide goods or services to you and fulfil our contract with you. This includes order fulfilment, processing of payment details, and the provision of support services.
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where we are legally required to do so.
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in order to facilitate the operation of our group of businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights.
We may transfer your personal information to the following countries and entities outside the EEA:
Zendesk, Inc: Privacy Shield
AWS: Privacy Shield
Datto, Inc (Backupify): Privacy Shield
Google LLC: Privacy Shield
HOW LONG WE KEEP YOUR INFORMATION
If you have subscribed to any of our newsletters, we retain Personal Information for as long as you remain subscribed. If you opt-out, we will retain only the minimum information needed to make sure you don't receive any unwanted communications from us.
We retain any first-party cookie information as set out in our Cookies section.
We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.
CONTENT & RECORDINGS
Content, including Recordings, and other information associated with Content (including but not limited to talent and other release agreements) is retained for:
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as long as is necessary in order to produce Content, and/or with a view to Publication, and/or
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for as long as the Content is Published on or through Luxe Varié.
Where we have a contract (including any image, rights or other release) with you, we may retain Content (and related personal data):
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in accordance with and for the length of any contract between us and you, including in order to meet our contractual obligations to you,
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for a period of time following any contract to produce and Publish our Content, maintain documentation of how we produced our Content, identify any issues and resolve any legal proceedings, and/or
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for as long as the relevant Content is available on or through Luxe Varié.
Our Content is Published on or through Luxe Varié, and will generally remain available on Bustle Digital Group for as long as Bustle continues to produce, Publish and store its Content.
Content and other information associated with it (including but not limited to talent and other release agreements) whether or not Published is retained by us, and may be used for Publishing in the future.
OUR GUIDELINES AND POLICIES
All Content, recordings (used and unused), and other information associated with the relevant Content (including but not limited to talent and other release agreements) are stored in accordance with our Content Library guidelines.
WHAT CHOICES DO I HAVE REGARDING MY INFORMATION?
You can always opt not to disclose certain information to us, even though it may be needed to take advantage of some of our features (e.g. newsletter sign-ups).
YOUR RIGHTS
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You have the right, under certain circumstances:
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to be provided with a copy of your Personal Information held by us;
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to request the correction or deletion of your Personal Information held by us;
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to request that we restrict the processing of your Personal Information (while we verify or investigate your concerns with this information, for example);
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to request that your provided Personal Information be moved to a third party; and
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to object to the further processing of your Personal Information in some circumstances.
Your right to withdraw consent:
Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us at info@luxevarie.com. You can also change your marketing preferences at any time as described in Our promotional updates and communications' section;
Please be aware that recordings made pursuant to an agreement between us and you (whether written, or when you enter an area we have posted Filming Notices around to let you know that filming is occurring), or, generally, any recordings made in public are not based on consent.
Your right to request correction or deletion:
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If you ask us to correct or delete your information, we’ll generally take steps to correct or delete your information as soon as we can where practicable, depending on the circumstances.
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In some circumstances, your right to deletion may be limited by applicable law, including where it must be balanced against our legitimate interests (taking into account the right of freedom of expression and information), and this may outweigh your rights. If your request relates to Content, for example, your right to deletion may not apply. However, we will consider each request in context.
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Depending on the circumstances, we may be entitled to retain, Publish and/or otherwise process Content for as long as is required for the purpose it was collected it for, or for similar, compatible purposes, including producing Content and our journalism. Some information may also remain in archived/backup copies for our records, or as otherwise required by law.
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If you have a particular concern about your personal information, please contact us to discuss this at info@luxevarie.com
Note that, as required by law, we will require you to prove your identity. We may verify your identity by phone call or email. Depending on your request, we will ask for information such as your name and email address. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to supply, correct or delete personal information about you in our files.
In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. We will require verification that you provided the authorized agent permission to make a request on your behalf. You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us. If you are an authorized agent submitting a request on behalf of an individual you must attach a copy of the following information to the request:
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A completed Authorized Agent Designation Form indicating that you have authorization to act on the consumer’s behalf.
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If you are a business, proof that you are registered with the Secretary of State to conduct business in California.
If we do not receive both pieces of information, the request will be denied.
Freedom of expression and information:
Your data protection rights must be reconciled with the rights of freedom of expression and information. Where our processing of personal data is for journalistic purposes or for the purposes of academic, artistic or literary expression, your rights to the protection of your personal data may not apply or may be outweighed by the rights to freedom of expression or information and/or our legitimate interests or rights.
The Information Commissioner is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your Personal Information, as well as deal with any complaints that you have about our processing of your Personal Information.
Your California Privacy Rights: If you are a California resident:
California Civil Code Sections 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 indicate that organizations should disclose whether certain categories of information are collected, “sold” or transferred for an organization’s “business purpose” (as those terms are defined under California law). Please note that because this list is comprehensive it may refer to types of information that we share about people other than you. Under California Civil Code section 1798.83, California residents who would like more information concerning the categories of personal information (if any) we share with third parties or affiliates for those parties to use for direct marketing, please submit a written request to us using the information in the "Contact Information" section below. This may not apply to information which comprises Content (i.e. as part of our journalistic and editorial activities).
We do not discriminate against California residents who exercise any of their rights described in this Privacy Policy.
ACCESSIBILITY
This privacy policy is accessible through your browser’s audio reader.
WHAT HAPPENS WHEN THERE ARE CHANGES TO THIS PRIVACY POLICY?
Any changes we make to this policy in future will be posted on this page. If we make any substantive changes, we will notify you by e-mail or through a pop-up within our Sites. Our privacy policy includes an “effective” and “last updated” date. The effective date refers to the date that the current version took effect. The last updated date refers to the date that the current version was last modified.
HOW TO OPT-OUT OF THIRD PARTY DATA TARGETING & HOW TO DISABLE COOKIES
If you prefer not to receive interest-based content and ads enabled by Google, you can opt-out by clicking on the “Opt Out” link at either Network Advertising Initiative (NAI) (http://optout.networkadvertising.org/#/) or Digital Advertising Alliance’s (DAA) (http://optout.aboutads.info/#/). Bustle is a registered Trustworthy Accountability Group (TAG) program participant with sourcing disclosure information available.
The effect of disabling cookies depends on which cookies you disable but, in general, the Sites may not operate properly if all cookies are switched off. If you want to disable cookies on our Sites, you need to change your website browser settings to reject cookies. How you can do this will depend on the browser you use.
Microsoft Internet Explorer
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Select the Tools menu > Internet Options
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Click on the Privacy tab
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Select the setting the appropriate setting
Google Chrome
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Select Settings > Advanced
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Under Privacy and Security > Content settings.
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Click Cookies and select the relevant options
Safari
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Select Preferences > Privacy
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Click on Remove all Website Data
Mozilla Firefox
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Choose the Tools menu > Options
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Click on the Privacy icon
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Select the Cookie menu and select the relevant options
Opera 6.0 and further
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Choose Files menu > Preferences
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Select Privacy
Where you have not set your permissions, we may also separately prompt you regarding our use of cookies on the Sites.