Privacy policy

Last updated: October 17, 2024

Privacy Policy

This Privacy Notice sets out how LaceSea Ltd. collects and uses (processes) information about individuals (referred to as your "personal information"). Personal information is information that by itself is available to us and can be used to identify you. In this privacy notice, we describe:


  1. Who Collects Your Personal Information
  2. Type Of Personal Information That We Collect
  3. How We Use Your Personal Information
  4. How We Share Your Personal Information
  5. Other Information We Collect
  6. Marketing Preferences
  7. Your Rights
  8. How Long We Keep Your Information
  9. Other Important Information


You may be assured that we will treat all personal information as confidential and will not process it other than for a legitimate purpose. Steps will be taken to ensure that the information is accurate, kept up to date and not kept for longer than is necessary. Measures are also taken to safeguard against unauthorised or unlawful processing and accidental loss or destruction or damage to the personal information.

Since this notice contains important information, we encourage you to read it. Please use the links to access detailed information. Any questions in relation to this Privacy Notice of requests in respect of personal information should be directed to hello@virgin-spirits.com in the first instance.

Who Collects Your Personal Information

Lacesea.com by LaceSea Ltd. is responsible for collecting and processing the personal information.

Whenever we refer to “we”, “us” or “our” in this notice, we mean Lacesea.com by LaceSea Ltd.


Type Of Personal Information That We Collect

We will hold and process data for day to day business process and activities including the processing of your orders for supply and sale of our products and services, to manage your account or to meet our Legal, Regulatory and Good Governance obligations and requirements (in particular in respect of anti -money laundering legislation). This list is not exhaustive and may be updated from time to time as dictated by business needs and legal and regulatory requirements.

If you do not provide the information that we request, we may not be able to provide you with the requested products or services.

Processing is as defined in the Regulations, but could include obtaining, recording or holding information or data. 

Personal data is information which can identify you as a living individual.


We will collect personal information when you:

  • Access our products and services
  • Create an account
  • Participate in a promotion, contest or attend an event
  • Make a purchase on one of our online stores or return something to us
  • Submit a review or participate in a survey
  • Communicate or interact with us via social media
  • Contact us for assistance
  • Submit an application for employment
  • You try to sell us products or services


Some of this information we collect directly from you either in person or via a website, via email or telephone contact, via web-chat, via Account Application and the Due Diligence Process or via social media.


The Personal Information we may collect from you explicitly includes the following:

  • Name, date of birth, gender and country of residence
  • Billing and shipping address
  • Personal contact information such as email address, telephone number and mobile number
  • Financial information (for Business customers only)
  • Account details such as user name, password and unique user ID
  • Payment information such as debit or credit card details; bank account details; PayPal User ID; Amazon User ID.
  • Photographic proof of age
  • Your reviews about our products and services, information about your preferences and consumption habits
  • Marketing communication and cookie preferences that you have given your consent
  • Education and Employment history, salary expectations (for job applications)
  • Details of your contact with us including recordings of any telephone calls
  • Photographs and videos submitted by you or taken at one of our events
  • Profile pictures and social media profile information that you have given your consent
  • Information about another individual. If you disclose any personal information relating to other people to us or to our service providers in connection with our products and services, you represent that you have the authority to do so and to permit us to use the information in according with this Privacy Policy.
  • Computer or device IP address


We also collect personal information about you from other sources. Such information from other sources may be:

  • Information from credit references, court records of debt judgements and bankruptcies or that received as part of routine card verification (fraud prevention) checks.
  • Social network information. When you use a social network login to access our services, you will share certain personal information from your social media account with us, for example, your name, email address, photo, list of social media contacts, and any other information that may be or you make accessible to us when you connect your social media account to your services account. The specific information transferred depends on your security settings and the privacy policy of your social media network.
  • Joint marketing partners, when they share information with us that you have given consent
  • Publicly available databases


When we receive personal information about you from different sources, we may combine or link that information. Linking different sources of information enables us to provide better customer support when you contact us and an overall better shopping experience.

Some of the personal data may be kept in paper files, while other personal data will be included in computerised files and electronic databases that have restricted and secure access.


How We Use Your Personal Information

We use data (including personal information of individuals) for the following purposes (the below also confirming the lawful basis we are relying in each case):


Purpose

Lawful Basis for Processing

Order Processing

We use personal information to perform and fulfil the contract we have entered into with the individual and process orders, to take payment for items purchased from us, to dispatch items purchased or to process a return or request for a refund.

We may also use personal data to protect against or identify possible fraudulent transactions. We will engage in these activities to manage our contractual relationship with the individual and/or to comply with a legal obligation.

In instances where an individual has been provided with this Privacy Notice and provided personal data thereafter, the processing may be carried out on the basis of the consent.

Customer Service

If you as an individual contact us, or we contact you, we will use your personal information such as your purchase information and contact history for the purpose of providing you with assistance, handling enquiries and complaints.

We will engage in these activities to manage our contractual relationship with you as an individual, for our legitimate business reasons and/or to comply with a legal obligation.

To provide you with Marketing Information and /or Information about our Products, Events or Services which may be of interest to you and manage such mailings.

Personal data to communicate with individuals on topics and events which may be of interest to them.

Where you as an individual have asked to receive marketing communications from us, we may send you information about our products, newsletters, promotions, offers or other information that we think might be of interest to you.

We use personal information to send you marketing communications via email, post, telephone and social media.

If you decide to opt-out from marketing messages, you may opt-out emailing hello@lacesea.com with the subject line ‘Opt-Out’. You can also log into your account online and opt-out.

We will seek to comply with your request(s) within 1 calendar month.

Our business purposes including legal, regulatory and governance obligations

As a supplier of the products and related services to process the personal data to the extent necessary as follows:

We use the personal information we hold about you to accomplish and manage our business purposes and contractual relationships and or to comply with a legal obligation, including:

• To conduct data analysis, for example, to improve the efficiency of our services;

• To conduct audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements;

• To monitor for fraud and security purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;

• To meet our legal, regulatory and governance obligations including as may be necessary for compliance;

• To consider ways for enhancing, improving, or modifying our current products and customer services;

• To identify usage trends, for example, understanding which parts of our services are of most interest to users;

• To determine the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and

• For operating and expanding our business activities, for example, understanding which parts of our services are of most interest to our users so we can focus our energies on meeting our users’ interests.

• For the purposes of our internal know – how and training

Security of staff and premises (including the use of CCTV equipment)

Protecting its systems, staff and premises from being misused or the victim of any criminal activity


How We Share Your Personal Information

Subject to applicable data protection law, we may share your personal information with your consent or as necessary to complete any transaction or provide any service you have requested. Sometimes the provision of data to one entity within our group may result in that data being accessible by all other members of our group. Reasonable endeavours are made to ensure that the data is only accessible by those with a need for access to fulfil the purposes set out above. We do not share your personal information with any third-party companies for the purpose of marketing including our affiliates unless you have explicitly provided us with consent.  We do not share your personal information with any third party outside of the European Union. The following are categories of recipients with whom we may share your personal data and for the reasons mentioned.


Purpose

Basis for Sharing Information

Business Transactions, Legal, Regulatory and Law Enforcement

• We have a legitimate interest in disclosing or transferring your personal information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.

• We may also disclose personal information to comply with legal and contractual obligations and our corporate policies and procedures and where we believe such action is necessary to – this may include:

o   Fraud prevention agencies, credit reference agencies, debt collection agencies when we open your account, other organisations who use shared data bases for income verification and credit checks,

o   Government bodies and agencies in the EU e.g. Revenue & Customs),

o   Any Registrar of a Public Register where the data is to be included in a Public Registry,

o   Courts and Tribunals to comply with legal requirements and for the administration of justice,

o   To protect the security, integrity, rights and privacy of our business operations,

o   To other parties connected with your account e.g. guarantors and other people named on the application

o   Anyone else where we have your consent or where it is required by law

Third Party Service Providers

• We use third party service providers to process personal information on our behalf. This may include:

o   Sub-contractors and other persons who help us provide our products and services,

o   Companies and other persons providing services to us including those who provide customer support, web hosting (including cloud based) and data base server providers, social media platforms, customer data management and list enhancement companies, marketing agencies that host our events and promotions or other marketing initiatives, companies that fulfil product orders, warehouse management or coordinate mailings, delivery and courier companies, market research organisations, product and service reviews providers

o   Payment processors, data analysis firms,

o   Legal, and other professional advisors including our accountants and auditors,

o   And where we enter into an engagement with a third party pursuant to which the data may be processed or shared by - with that third party, we will seek to enter into an agreement with that third party setting out the respective obligations of each party and we will endeavour to be reasonably satisfied that the third party has measures in place to protect the data against unauthorised or accidental use, access, disclosure, damage , loss or destruction.


Other Information We Collect

We and our service providers also may collect other information that does not reveal your specific identity or does not directly relate to an identifiable individual (referred to as “other information”). This may include:

  • Server log files and environmental variables
  • App usage data
  • Information collected through cookies, pixel tags and other technologies
  • Demographic information and other information provided by you that does not reveal your specific identity
  • Information that has been aggregated in a manner such that it no longer reveals your specific identity

If we are required to treat other information as personal information under applicable law, then we may use and disclose it for the purposes for which we use and disclose personal information detailed in this Policy.


Other information may be collected in a variety of ways, including:

  • Through your browser or device
  • Through your use of one of our mobile apps
  • Using cookies; Please read our 

Cookie Policy

  • Using pixel tags and other similar technologies: Our websites may also provide us with information including details of the content you access and interact with. We use cookies and other technologies to collect information about your device browser and operating system, IP address, links you click and pages you open, which we then use to tailor marketing messages. We will provide personalised services either with your consent or because we have a legitimate interest.


Marketing Preferences

  • Unless you have told us not to, we will send you marketing information relating to products and promotions that we think will be of interest and relevant to you. If you change your mind and no longer wish to receive these communication, you can tell us at any time by contacting us at hello@lacesea.com. If you have previously told us that you don’t want information on our products and promotions, we will continue to respect your wishes.

Your Rights

Data subjects in the European Union (or any jurisdiction with equivalent legislation to the European Union General Data Protection Regulation) have certain rights in respect of their personal data.  We will respond to your requests consistent with applicable law. These rights are as follows:

  • The right to be informed about our processing of your personal data
  • The right to have your personal data corrected if it is inaccurate and to have incomplete personal data completed
  • The right to object to processing your personal data
  • The right to restrict processing of your personal data
  • The right to have your personal data erased (the ‘’right to be forgotten’’) - if you do not want to receive promotional emails you may inform us at any time by contacting us at hello@lacesea.com
  • The right to request access to your personal data and information about how we process your data
  • The right to move, copy or transfer your personal data ("data portability")
  • Rights in relation to automated decision making including profiling

Should you wish to exercise your rights under the applicable data protection laws, please send such requests in the first instance to hello@lacesea.com.

You have the right to complain to the Information Commissioner’s Office at www.en.gouv.mc

In any case in which a data subject chooses not to provide any personal data or where any of the rights set out are exercised to limit the processing of personal data, lacesea.com by Spirits Media Group S.A.R.L. may be unable to provide the relevant products or services, or there may be a restriction on the services which can be provided.


How Long We Keep Your Information

We retain personal information only for as long as needed or permitted in light of the purposes (as set out above) for which it was obtained and consistent with applicable law. The criteria which we use to determine data retention periods for your personal data include the following:

  • Retention in case of an ongoing relationship: The length of time we have an ongoing relationship with you and provide the products and services to you (for example, for as long as you have an account with us or keep using the services);
  • Retention in accordance with legal, regulatory and statutory requirements: Whether there is a legal obligation to which we are subject and where the data cannot be deleted for legal, regulatory or statutory reasons; or
  • Whether retention is advisable in light of protecting our legal position: in the case of disputes and court claims (such as in the case of termination of employment)
  • Others: In the absence of any statutory requirement, our retention policies will be proportionate and designed using a risk-based approach.

Any requests for further information in relation to the continued processing of specific data and requests for the destruction of data should be made to hello@lacesea.com


Other Important Information

If you have any questions, concerns or require further information on how we control or process your personal information then we welcome you to contact us:

Email: Data Protection Officer - hello@lacesea.com

Post: Data Protection Officer, Spirits Media Group S.A.R.L, 1 Boulevard Princesse Charlotte, 98000 Monaco

Our last update to this privacy policy was on 27th August 2024.. For every future update to our policy will communicate this to our customers via email.

 

 

Cookie Policy

This privacy policy sets out how uses and protects any information that you give Spirits Media Group S.A.R.L. when you use this website. lacesea.com is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement. lacesea.com by Spirits Media Group S.A.R.L.  may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes.

WHAT WE COLLECT

We may collect the following information:

  • name
  • contact information including email address
  • demographic information such as postcode, preferences and interests
  • other information relevant to customer surveys and/or offers

For the exhaustive list of cookies we collect see the List of cookies we collect section.

WHAT WE DO WITH THE INFORMATION WE GATHER

We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:

  • Internal record keeping.
  • We may use the information to improve our products and services.
  • We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided.
  • From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, fax or mail. We may use the information to customise the website according to your interests.

SECURITY

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

HOW WE USE COOKIES

A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

LINKS TO OTHER WEBSITES

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

CONTROLLING YOUR PERSONAL INFORMATION

You may choose to restrict the collection or use of your personal information in the following ways:

  • whenever you are asked to fill in a form on the website, look for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes
  • if you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or emailing us at hello@lacesea.com

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.

You may request details of personal information which we hold about you under the Data Protection Act 1998. A small fee will be payable. If you would like a copy of the information held on you please write to .

If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.

LIST OF COOKIES WE COLLECT

The table below lists the cookies we collect and what information they store.

COOKIE name

COOKIE Description

AGEGATE

If you were asked to verify your age on entry to the site

AWIN

If you landed on our website via an Affiliate

CART

The association with your shopping cart.

CATEGORY_INFO

Stores the category info on the page, that allows to display pages more quickly.

COMPARE

The items that you have in the Compare Products list.

CURRENCY

Your preferred currency

CUSTOMER

An encrypted version of your customer id with the store.

CUSTOMER_AUTH

An indicator if you are currently logged into the store.

CUSTOMER_INFO

An encrypted version of the customer group you belong to.

CUSTOMER_SEGMENT_IDS

Stores the Customer Segment ID

EXTERNAL_NO_CACHE

A flag, which indicates whether caching is disabled or not.

FRONTEND

You sesssion ID on the server.

FACEBOOK

Allows us to track activity if you have visited us from a META platform such as Facebook or Instagram.

GOOGLE

Several google cookies are used to track your activity. No personal information is collected

GUEST-VIEW

Allows guests to edit their orders.

LAST_CATEGORY

The last category you visited.

LAST_PRODUCT

The most recent product you have viewed.

NEWMESSAGE

Indicates whether a new message has been received.

NO_CACHE

Indicates whether it is allowed to use cache.

PERSISTENT_SHOPPING_CART

A link to information about your cart and viewing history if you have asked the site.

POLL

The ID of any polls you have recently voted in.

POLLN

Information on what polls you have voted on.

RECENTLYCOMPARED

The items that you have recently compared.

STF

Information on products you have emailed to friends.

STORE

The store view or language you have selected.

USER_ALLOWED_SAVE_COOKIE

Indicates whether a customer allowed to use cookies.

VIEWED_PRODUCT_IDS

The products that you have recently viewed.

WISHLIST

An encrypted list of products added to your Wishlist.

WISHLIST_CNT

The number of items in your Wishlist.

 

Contact

Should you have any questions about our privacy practices or this Privacy Policy, or if you would like to exercise any of the rights available to you, please call or email us at hello@lacesea.com.

For the purpose of applicable data protection laws and if not explicitly stated otherwise, we are the data controller of your personal information.