Privacy Policy

  1. Introduction

Little Luxury respects your privacy and is committed to protecting your personal information.

This Privacy Policy explains how we collect, use, store, share and protect personal information when you visit or use littleluxury.co.za, purchase our products, create an account, contact us, subscribe to our communications or otherwise interact with Little Luxury.

This Privacy Policy has been prepared in accordance with the Protection of Personal Information Act 4 of 2013 (“POPIA”) and other applicable South African laws relating to privacy and the protection of personal information.

POPIA establishes minimum requirements for the lawful processing of personal information and regulates, among other things, electronic direct marketing and transfers of personal information outside South Africa. (Government of South Africa)

  1. Who We Are

Little Luxury is a brand operated by:

Responsible Party: Affordable Brands
Trading as: Little Luxury
Website: littleluxury.co.za
Email: info@littleluxury.co.za

Telephone: +27 11 784 4444

Physical/Business Address: 94 11th Street, Parkmore, Sandton 2196

For purposes of POPIA, the above entity is the Responsible Party in respect of personal information processed through this website and our South African business operations.

  1. Information Officer

Our Information Officer is responsible for overseeing compliance with POPIA and dealing with enquiries and requests relating to personal information.

Information Officer: Little Luxury Customer Service
Email: info@littleluxury.co.za
Telephone: +27 11 784 4444

Questions concerning this Privacy Policy or the way in which we process personal information may be directed to our Information Officer.

  1. Personal Information We Collect

Depending on how you interact with Little Luxury, we may collect and process information including:

  • your name and surname;
  • email address;
  • telephone or mobile number;
  • billing and delivery addresses;
  • account username and account information;
  • order and transaction history;
  • products purchased or viewed;
  • customer service enquiries and correspondence;
  • product reviews or other information you voluntarily submit;
  • marketing and communication preferences;
  • information you provide when participating in competitions, promotions or surveys;
  • IP address and device information;
  • browser type and website usage information;
  • information collected through cookies and similar technologies; and
  • other information reasonably necessary to provide our products and services to you.

Where payments are made through a third-party payment provider, payment information may be processed directly by that provider. We do not intentionally retain complete payment-card details unless necessary and lawfully permitted.

We will endeavour to collect only personal information that is adequate, relevant and reasonably necessary for the purpose for which it is processed.

  1. How We Collect Personal Information

We may collect personal information directly from you when you:

  • purchase a product through our website;
  • create or update an account;
  • complete a form;
  • contact us by email, telephone, website form or another communication channel;
  • subscribe to marketing communications;
  • enter a competition or promotion;
  • submit a review;
  • communicate with customer service; or
  • otherwise provide information to us.

We may also collect certain information automatically when you use our website through cookies and similar technologies.

In appropriate circumstances, information may also be received from third parties such as service providers, payment providers, delivery providers, marketing platforms, analytics providers, retailers, social-media platforms or business partners.

Where POPIA requires information to be collected directly from you, we will do so unless an applicable exception permits collection from another source.

  1. Why We Process Your Personal Information

We may process your personal information to:

  • process and fulfil your orders;
  • arrange payment and delivery;
  • manage your Little Luxury account;
  • communicate with you regarding an order or transaction;
  • provide customer service and respond to enquiries;
  • process returns, refunds, warranties or complaints;
  • maintain appropriate business, accounting and transaction records;
  • prevent or investigate fraud, misuse or security incidents;
  • improve our website, products and services;
  • understand how customers use our website;
  • administer competitions, promotions or surveys;
  • send marketing communications where permitted by law;
  • comply with legal and regulatory obligations;
  • establish, exercise or defend legal rights; and
  • otherwise operate and administer our business.

We will not process personal information for a purpose that is incompatible with the purpose for which it was originally collected unless such further processing is permitted by POPIA.

  1. Lawful Processing of Personal Information

We process personal information only where permitted under POPIA and applicable law.

Depending on the circumstances, this may include processing where:

  • you have consented to the processing;
  • processing is necessary to perform a contract with you;
  • processing is necessary to take steps requested by you before entering into a contract;
  • processing is required to comply with a legal obligation;
  • processing protects a legitimate interest of yours;
  • processing is necessary for the proper performance of a public-law duty by a public body; or
  • processing is necessary for pursuing our legitimate interests or those of a third party, subject to your rights and interests under POPIA.

Where we rely on consent, you may withdraw that consent, subject to applicable law and any consequences of withdrawal.

  1. Online Purchases and Payments

When you purchase a product through our website, we process information necessary to complete the transaction, including your contact, billing, delivery and order information.

Payment transactions may be processed by third-party payment service providers. Those providers may process your information in accordance with their own privacy policies and applicable legal requirements.

We take reasonable steps to ensure that service providers processing personal information on our behalf implement appropriate safeguards.

  1. Direct Marketing and Email Communications

We may send you marketing communications about Little Luxury products, promotions, offers or news where permitted by POPIA.

We will not automatically add every person who places an order or makes an enquiry to a general marketing list merely because we have obtained their email address.

Where required by POPIA, we will obtain consent before sending unsolicited electronic direct marketing.

Where you are an existing customer, POPIA may permit us to use contact details obtained in connection with the sale of a product or service to market our own similar products or services, provided the applicable requirements of POPIA are satisfied.

You will be provided with an opportunity to object to eligible direct marketing when your information is collected and in each subsequent marketing communication, as required by applicable law.

You may unsubscribe from marketing emails at any time by using the unsubscribe link contained in our marketing emails or by contacting us.

Unsubscribing from marketing communications will not prevent us from sending transactional or service communications that are necessary in connection with an order, account, warranty, customer service enquiry or other existing relationship.

The Information Regulator specifically identifies email, SMS, telephone calls and push notifications as forms of electronic communication to which POPIA’s direct-marketing provisions can apply. (Empowered Compliance)

This section is particularly important for your Mailchimp/WooCommerce setup. It replaces the current wording stating that customers may automatically be added to your marketing list after placing an order or making an enquiry. Your existing policy currently contains that wording.

  1. Cookies and Similar Technologies

Our website may use cookies and similar technologies to operate correctly, remember preferences, understand how visitors use the website, improve website performance and, where applicable, support advertising and marketing activities.

Cookies may collect information such as:

  • IP address;
  • browser and device type;
  • pages visited;
  • referring website;
  • interactions with our website;
  • shopping-cart activity; and
  • website usage information.

Some cookies are necessary for the website and online store to function. Other cookies may be used for analytics, functionality or advertising.

Where required, visitors will be provided with appropriate choices concerning non-essential cookies.

You can also control certain cookies through your browser settings. Disabling cookies may affect the functionality of some parts of our website.

  1. Sharing Personal Information

We do not sell or rent your personal information to third parties for their own marketing purposes.

We may disclose personal information where reasonably necessary to:

  • website hosting and technology providers;
  • payment processors;
  • courier and delivery providers;
  • email and marketing service providers;
  • analytics providers;
  • professional advisers such as accountants, auditors and legal advisers;
  • IT and security providers;
  • customer-service providers;
  • regulators, law-enforcement authorities or government bodies where required by law; and
  • a purchaser or successor in connection with a lawful sale, merger or restructuring of all or part of our business.

Where a service provider processes personal information on our behalf as an operator, we take reasonable steps to ensure that appropriate privacy and security requirements apply.

Your existing policy already establishes the principle that service providers should only use customer information to provide their services.

  1. International Transfers of Personal Information

Some of our service providers or technology platforms may process or store personal information outside South Africa.

Where personal information is transferred outside South Africa, we will do so in accordance with section 72 of POPIA.

This may include circumstances where:

  • the recipient is subject to a law, binding corporate rules or binding agreement that provides an adequate level of protection;
  • you consent to the transfer;
  • the transfer is necessary for the performance of a contract between you and us;
  • the transfer is necessary for the implementation of pre-contractual measures taken at your request;
  • the transfer is necessary for the conclusion or performance of a contract concluded in your interests; or
  • another basis permitted by POPIA applies.

The Information Regulator similarly recognises adequate protection, consent and certain contractual circumstances as grounds for cross-border transfers under section 72. (Empowered Compliance)

This replaces the current policy’s much broader statement that using the website constitutes consent to transfers to countries outside South Africa.

  1. Security of Personal Information

We take reasonable and appropriate technical and organisational measures to protect personal information against:

  • loss or damage;
  • unauthorised destruction;
  • unlawful access;
  • unauthorised processing;
  • alteration; and
  • disclosure.

These safeguards may include appropriate access controls, secure systems, encryption and other reasonable security practices.

Although we take reasonable precautions, no internet transmission or electronic storage system can be guaranteed to be completely secure.

Where we become aware of a security compromise involving personal information, we will take appropriate action and provide notifications to the Information Regulator and affected data subjects where required by POPIA.

The requirement to notify data subjects of applicable security compromises is expressly recognised by the Information Regulator. (Empowered Compliance)

  1. Retention of Personal Information

We retain personal information only for as long as reasonably necessary to achieve the purpose for which it was collected or subsequently processed, unless:

  • retention is required or authorised by law;
  • we reasonably require the information for lawful purposes relating to our business;
  • retention is required by an agreement; or
  • you have consented to its retention.

When personal information is no longer required and we are not legally entitled or required to retain it, we will delete, destroy or de-identify it as appropriate.

This develops the retention principle already contained in your current policy.

  1. Your Rights Under POPIA

Subject to applicable law, you have the right to:

  • be informed that your personal information is being collected;
  • request confirmation of whether we hold personal information about you;
  • request access to personal information we hold about you;
  • request correction of inaccurate, irrelevant, excessive, outdated, incomplete or misleading information;
  • request deletion or destruction of personal information that we are no longer authorised to retain;
  • object to the processing of personal information in appropriate circumstances;
  • withdraw consent where processing is based on consent;
  • object to direct marketing;
  • be notified of certain security compromises involving your personal information;
  • not be subject, in applicable circumstances, to certain decisions based solely on automated processing; and
  • lodge a complaint with the Information Regulator.

These rights are reflected in POPIA and in the Information Regulator’s current privacy guidance. (Empowered Compliance)

  1. Accessing, Correcting or Deleting Your Information

If you have an online account, certain personal information may be viewed or updated through your account.

You may also contact our Information Officer to request:

  • confirmation that we hold your personal information;
  • access to your personal information;
  • correction of your information;
  • deletion or destruction where permitted;
  • withdrawal of consent; or
  • an objection to certain processing.

We may need to verify your identity before acting on a request to protect your personal information from unauthorised disclosure or alteration.

Requests will be handled in accordance with POPIA, PAIA and other applicable law.

  1. Children’s Personal Information

Our website and products are not intended to collect personal information from children without appropriate authorisation.

Where we knowingly process the personal information of a child, we will do so only where permitted by POPIA, including where the consent of a competent person has been obtained or another lawful basis applies.

If you believe that a child has provided personal information to us without appropriate authorisation, please contact our Information Officer.

  1. Third-Party Websites and Services

Our website may contain links to websites, social-media platforms or services operated by third parties.

We do not control the privacy practices of independent third parties and recommend reviewing their privacy policies before providing personal information to them.

Where a third party processes information on our behalf as our operator, different obligations may apply under POPIA.

  1. Complaints

If you have concerns about the way Little Luxury processes your personal information, please contact our Information Officer first so that we can investigate and respond to your concern.

You also have the right to lodge a complaint with the Information Regulator (South Africa).

Information Regulator (South Africa)
Telephone: 010 023 5200
Email: enquiries@inforegulator.org.za

Information Regulator South Africa

The Information Regulator is the independent body established under section 39 of POPIA with jurisdiction throughout South Africa. (Empowered Compliance)

  1. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to our business practices, technologies, services or legal and regulatory requirements.

The latest version will be published on this website and the Last Updated date at the top of this policy will be amended accordingly.

Where a change materially affects the way we process personal information, we will take reasonable steps to provide appropriate notice where required.

  1. Contact Us

For questions about this Privacy Policy, POPIA or the personal information we hold about you, please contact:

Little Luxury
Responsible Party: Affordable Brands
Information Officer: Little Luxury Customer Service
Email: info@littleluxury.co.za
Telephone: +27 11 784 4444
Address: 94 11th Street, Parkmore, Sandton 2196