Open Quarter 2019

Privacy Policy​

Introduction

Lubna Gem Arielle (we or us) cares about the privacy of your personal information and is committed to protecting it. This Privacy Policy (Policy) explains what information we collect about you and why, what we do with that information, and how we handle that information.

For the purposes of the applicable data protection laws (the General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR), together with any implementing legislation, in particular, the Data Protection Act 2018), the person responsible for your personal information is Lubna Gem Arielle. This Policy is incorporated into our Terms and Conditions (Terms & Conditions) and applies to information obtained by us through your use of the information made available through our website (Website).

Collection of your Personal Information

We collect information that, alone or in combination with other data, could be used to identify you (Personal Information), such as your e-mail address or name. We will collect your Personal Information in a number of ways, including when you contact us through the Website, by telephone, post or e-mail.

Automatically collected information

When you visit our Website, we automatically collect information about your computer hardware and software such as your IP address, browser type, domain names, access times, operating system, cookie information, referring website addresses, pages visited, links clicked, text entered, mouse movements, and Internet Service Provider. We analyse and use this information to better understand how our users use the service, to maintain and improve our service, and in some cases, to publicly disclose aggregated statistics regarding our services.

Use of your Personal Information

We collect and use your Personal Information as necessary for our legitimate business interests, including to:

• operate the Website and deliver any services.

• communicate with you to respond to any communication from you.

Storage of Personal Information

Unless a longer retention period is required or permitted by law, we will only hold your Personal Information on our systems for the period necessary to fulfil the purposes outlined in this Policy, or until you request that the information be deleted in accordance with your right of erasure (see "Your rights" section below).

Even if we delete your Personal Information, we reserve the right to maintain a copy for legal, tax or regulatory purposes, but in such event, we will do so only as long as necessary to fulfil those legal, tax or regulatory purposes. Please contact us for more information using the Contact Information at the end of this Policy.

Personal Information access and disclosure

We will only disclose Personal Information to third parties:

• when we use vendors, lawyers and service providers to assist us in meeting business or operating needs, such as providing legal services, hosting our Website, communicating with users, delivering and improving our services, e-mail communication, invoicing and payments, customer support services and analytics.

These service providers may only access, process or store Personal Information pursuant to our instructions and to perform their duties to us, and in accordance

with applicable laws and regulations; or

• when we have your explicit consent to share your Personal Information; or

• when we determine that disclosure is required to protect our rights, property, or personal safety or that of other users of the Website, or to respond to lawful subpoenas, warrants, or requests by public or regulatory authorities, including requests by law enforcement authorities.

Transfers outside of the EEA

As part of the services offered to you through the Website, the Personal Information you provide to us may be transferred to and stored in countries outside of the European Economic Area (EEA). By way of example, a transfer of your Personal Information may happen if one of our service providers is located in a country outside of the EEA. We will only transfer Personal Information outside of the EEA where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your Personal Information, for example, by way of data transfer agreement incorporating the current standard contractual clauses adopted by the European Commission, or by self-certifying to the EU-US Privacy Shield Framework in the event that

Use of cookies

The Website uses "cookies" to help you personalise your online experience. A cookie is a text file that is placed by us on your hard drive by a web page server. Our cookies do not run programs or deliver viruses to your computer. Cookies are uniquely assigned to your computer, and can only be read by a web server in the domain that issued the cookie to your computer.

We may place the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of the Website.

• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. This helps us to improve the way our Website works.

If you want to check or change what types of cookies you accept, this can usually be done within your browser settings. Please note that third parties (including, for example, providers of external services like web traffic analysis services) may also use cookies, over which we have no control.

How to reject cookies

If you do not want to receive cookies, you can usually choose to opt-out by modifying your browser settings to decline them. If you choose to decline cookies, you may not be able to access all or parts of, or to fully experience the web pages you visit. For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. This site also provides details on how to delete cookies from your computer.

Data security & integrity

We are committed to taking reasonable and appropriate steps to protect the Personal Information that we hold from misuse, loss, or unauthorised access. We do this by using a range of technical and organisational measures including measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your personal information, please let us know immediately, using the Contact Details at the end of this Policy.

The Website is designed to secure the Personal Information you provide on computer servers in a controlled, secure environment, with protections from unauthorised access, use or disclosure.

However, while we do our best to protect your Personal Information, we cannot guarantee the security of all data which is transmitted to the Website or to another website via the internet or similar connection.

Your rights

Under the GDPR, you have various rights in relation to your Personal Information, such as the rights of access, rectification, restriction, objection, portability, and erasure. Please note that these rights are subject to certain limitations set forth in applicable law.

To exercise these rights, please contact us using the Contact Details at the end of this Policy. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of applicable laws. Please note that we may keep a record of your communications to help us resolve any issues you raise.

You also have the right to lodge a complaint with your local supervisory authority (for UK residents, the Information Commissioner’s Office, or ICO) if you believe we have failed to meet our obligations regarding your Personal Information.

Links to third party websites

Our Website includes links to other websites whose privacy practices are not under our control. If you submit Personal Information to any of those websites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy on any website that you visit.

Children

We do not intend to solicit or collect Personal Information from anyone under the age of 18. If you are under 18, do not enter information on this Website.

Changes to this Policy

We will occasionally update this Policy and encourage you to periodically review this Policy to be informed of how we are protecting your Personal Information.

Contact information

We welcome your comments regarding this Policy. Please contact us at hello@lubnagemarielle.com, or write to us at:

Data Protection Officer Lubna Gem Arielle 42 The Old High Street Folkestone, Kent, UK

For more information, please review our Terms & Conditions.