We are committed to the protection of your personal information.

This policy (the “Policy”) sets out how we collect, use, manage and store personal information during the course of business. You agree that this Policy applies to you as an individual and is separate from, and does not amend or modify, any contractual arrangements between you or your organisation and us, nor create any rights in you under any such contract.

1. Terminology

In this Policy:

• “personal information” means any information or opinion about an identified individual or an individual who is reasonably identifiable (whether or not the information is true);
• “sensitive information” means (without limitation) information about an individual’s race, ethnic origin, membership of a political association, religious beliefs, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation, criminal record, or health, genetic or biometric information;
• “we,” “us,” “our,” and “LT Iconic Agency” are reference to LT Iconic Agency.
• “you” and “your” means an individual whose personal information we have collected.

2. To Whom Does The Privacy Apply?

This Privacy Policy applies to three groups: you are an influencer in our network (or potential influencer), you are a client of ours, you are a subscriber to our newsletter. Most data is collected from the first two groups.

When you are an influencer, we may obtain information about you via your public profile on social media or via your public website(s). Also, we may have received information directly from you or your agent/management in relation to our contractual relationship. We may also obtain information from third parties, such as social media channels or other digital service providers on the effect of your posts. When you are a potential influencer, the information that we process originates from your public social media profiles or your public website(s) or directly from you or your agent/management. When you are client, you provide us with the correct information.

3. What Personal Information is Collected

We require customers to register and create an account on our website in order to make purchases. This registration requires you to fill out certain personal information. The information required, depending on the context, include but are not limited to:

• your full name;
• company name
• telephone, mobile phone number and email address;
• address
• age or birth date;
• employment related information, if you apply to work for us;
• information you provide to us through surveys, competitions or market research; and
• any other personal information you or a person ostensibly authorised by you submits to us, as well any other information that we consider necessary (such as information about your opinions) to perform our functions and activities.
• social media channels and/or websites
• social media/website statistics including: numbers of followers, engagement/reach, demographics of followers, gender/age of followers,
• social security numbers
• bank details

The personal data may originate from various sources. We may process personal data that we have found on your public profile on social media or your public website to the extent you have made this information public intentionally and not solely for private purposes. When you are an influencer or former influencer we will process personal data that we have obtained in connection with our previous cooperation. This data may originate from your agreement with us, from your social media profile(s) or website(s) and from information you (or your agent/manager) provided to us.

4. Purpose of collection, use and disclosure

4.1 We collect, use and disclose personal information for the primary purpose of conducting our business, which includes:

1. providing and managing the delivery of our services and products, including processing orders and delivering products; 
2. collecting and disclosing personal information to our related entities in connection with our operations;
3. in the case of applications for employment, assessing a person’s application for employment with us;
4. to assess the performance of the website and to improve the operation of the website;
5. researching and assessing our services and products to identify possible improvements, including collecting, using, and disclosing details about your usage patterns and interests;
6. for the administrative, marketing (including direct marketing), planning, product or service development, quality control and research purposes;
7. responding to an inquiry or request;
8. compiling and maintaining a mailing list and communicating with persons on those lists;
9. fulfilling obligations to, and cooperating with, government authorities;
10. resolving disputes or addressing complaints;
11. protecting our property, rights, and security, and the rights, property, and security of third parties or the public in general; and
12. disclosing business-related data and information (including personal information) to potential buyer or other successors in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, insolvency, liquidation, or similar proceedings.

5. To whom may we disclose your personal information?

5.1 In conducting our operations, we may share some of your personal information with, or receive personal information from, third parties such as outsourced service providers and contractors.

5.2 Unless you have agreed otherwise, these parties are not allowed to use your personal information for any other purpose except to assist in conducting our business. We take reasonable steps to ensure that such third parties are subject to confidentiality requirements. In particular, we may disclose your personal information:

1. to third party technology providers including Shopify and NetSuite which are online solutions we use to process customer orders and manage internal human resource functions;
2. through Electronic Data Interchange (EDI);
3. in the case of employees, to third parties that manage our payroll system and employee records;
4. to any other third parties incidental to us carrying out our functions; 
5. to other service providers or referral partners in order to provide our services to you, or to assist our functions or activities (such as law firms);
6. where you otherwise provide your consent, whether express or implied; and
7. where otherwise required by law.

6. Storage and security of personal information

6.1 Where we hold your personal information, we will take reasonable steps to ensure that the information is secure and may only be accessed by authorised persons. Where we store your personal information electronically on our database, we use secure servers and there are restrictions as to who has access to that information through password protection. All hardcopies of personal information are stored in lockable rooms.

6.2 Although we take reasonable steps, we are not responsible for third party circumvention of security measures on our electronic databases or at any of our premises. Please note that third party recipients of personal information may have their own privacy policies and we are not responsible for their actions, including their handling of personal information.

6.3 We cannot control the actions of other users with whom you share your information. Further, we cannot guarantee that only authorised persons will access your personal information. Please notify us immediately if you believe there has been any unauthorised access to your information.

6.4 We keep personal information as long as it is reasonably necessary for the purposes described in this Policy or otherwise in compliance with our or our service providers’ data retention policies. If any personal information that we hold is no longer required for the purpose for which it was collected and no applicable law requires us to retain that information, we will take reasonable steps to de-identify or destroy the information.

7. Access and correction

7.1 We will take reasonable steps to ensure the personal information we hold is complete, up to date and accurate, so far as it is practicable for us to do so.

7.2 You may request access to the personal information we hold about you by contacting our Privacy Officer. We may, subject to any exceptions set out in the Privacy Act, provide you with access to your personal information. We may charge you a fee to cover our administrative and other reasonable costs for giving access but we will not charge you for making the request itself.

7.3 Subject to paragraph 7.4, if personal information we hold about you is incorrect, we will, on your request to correct it or where we are satisfied that the information is inaccurate, out of date, incomplete, irrelevant or misleading, take such steps as are reasonable in the circumstances to ensure that the information is corrected. You are able to make a correction request by using the contact details below. We will not charge you for making a correction request.

7.4 If you request us to correct personal information that we hold about you and we refuse to do so, we will, to the extent reasonable, provide you a written response as to our reasons. You can make a complaint if you think we have wrongly refused to correct or give you access to your personal information by using the contact details below.

8. Direct marketing

8.1 From time to time, we may use your personal information for direct marketing purposes and you consent to us using your personal information for direct marketing purposes (for an indefinite period). This includes sending you updates about our products and offerings. When we contact you, it may be by mail, email or SMS. If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so. Where we use or disclose your personal information for the purpose of direct marketing, we will:

(a) allow you to ‘opt out’ or, in other words, allow you to request not to receive direct marketing communications; and
(b) comply with any such request by you to ‘opt-out’ of receiving further communications within a reasonable time frame.

8.2 You may ask to be removed from our marketing lists at any time by directly contacting us. If you don’t wish to receive direct marketing materials, contact our Privacy Officer using the details set out at the end of this Privacy Policy.

9. Your Rights

You have certain rights in relations to the processing of your personal data. You can at any time, with reasonable intervals, exercise your right of inspection of your personal data. Upon inspection, you can request us to correct or delete your personal data if the data is incorrect or excessive. To the extent your personal data is being processed based on your consent, you may withdraw your consent at any time. In order to exercise your rights please contact us via email. We may ask you in response to your request to identify yourself. Like any data subject, you will always have the right to issue a complaint with the competent data protection authority in case of violation of the applicable data protection laws and regulations which affects your privacy. The German Privacy Act (Bundesdatenshutzgesetzt – BDSG) is Germany’s implementation of the General Data Protection Regulation (GDPR).

10. Changes to this Policy

We may change this Policy at any time. Please refer back to this Policy periodically to review any updates. If we make material changes to this Policy we will notify you by publication on our website. The revised version of the Policy will be effective at the time we post it, which time will be indicated at the end of this Policy. You agree to be bound by any modified or amended versions of this Policy.