Privacy Policy

Document updated on 07/22/2024

LIGHTHOUSE CONSULTANCY SERVICE LIMITED (“LIGHTHOUSE CONSULTANCY SERVICE LIMITED”, “us”, “we” and “our”) and our partners respect your privacy.
We ask that you please read this privacy policy carefully to understand how your personal data is collected, processed and stored during your use of this Lighthouse Hospitality website, accessible via the URL www.lighthouse.com.
The term “personal data” means any information relating to a natural person and allowing them to be identified, directly or indirectly, from a single piece of data or from the cross-referencing of a set of data.
All personal data collected on this website are processed under the responsibility of the company LIGHTHOUSE CONSULTANCY SERVICE LIMITED, Ltd, registered under company registry number 618415400000823, and having its registered office at 29/F, Singga Commercial Centre, 148 Connaught Rd W, Sai Ying Pun and in compliance with Law No. 78-17 of January 6, 1978 relating to computing, files and freedoms, in its current version, as well as Regulation (EU) 2016/ 679 of April 27, 2016 relating to the protection of individuals with regard to the processing of personal data and the free movement of such data.
Within the meaning of the regulations applicable to personal data, LIGHTHOUSE CONSULTANCY SERVICE LIMITED is therefore responsible for processing.
This privacy policy describes:
1. How LIGHTHOUSE CONSULTANCY SERVICE LIMITED uses your personal data
2. How LIGHTHOUSE CONSULTANCY SERVICE LIMITED shares your personal data
3. How LIGHTHOUSE CONSULTANCY SERVICE LIMITED protects your personal data
4. Where LIGHTHOUSE CONSULTANCY SERVICE LIMITED hosts and transfers your personal data
5. How you can exercise your rights relating to your personal data
6. Privacy Policy Updates
7. How to contact us
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I. How LIGHTHOUSE CONSULTANCY SERVICE LIMITED uses your personal data
LIGHTHOUSE CONSULTANCY SERVICE LIMITED may use your personal data for the following purposes:
(1) Carry out the actions necessary for the management of contracts, invoices and customer relationship monitoring
(2) Publish and manage your opinions and/or comments left on the website
(3) Send you our newsletter, if you are subscribed to it
(4) Respond to your contact request made from our website
(5) Establish a loyalty program
(6) Offer you advertisements and tailored content
(7) Create a file of users, prospects and customers
(8) Develop commercial and attendance statistics
(9) Manage unpaid debts and possible disputes
(10) Comply with our legal obligations

The processing of your personal data is carried out in a pre-contractual contact process, this processing is based on your consent to be contacted in order to discuss our offers and obtain a quote. You can withdraw this consent at any time and request that we delete your information and stop contacting you.
When you voluntarily provide us with personal data, the collection of your personal data is based on the following legitimate interest: to better respond to your requests for information.

The processing of your personal data in order to send you our newsletter is, however, based solely on your consent to receive our newsletter, which you can withdraw at any time. If you do not consent to the sending of the newsletter, please note that this will not prevent you from creating your customer account and placing orders on our website.

II. How LIGHTHOUSE CONSULTANCY SERVICE LIMITED shares your personal data
Within LIGHTHOUSE CONSULTANCY SERVICE LIMITED, and with regard to each processing purpose, personal data concerning you are collected, processed and stored by authorized personnel of LIGHTHOUSE CONSULTANCY SERVICE LIMITED, solely within the framework of their respective skills, and in particular by customer service, the marketing department and the IT department.
We do not share personal data with other companies, organizations and individuals unless one of the following circumstances applies:

(1) Sharing with prior consent: after obtaining your consent, LIGHTHOUSE CONSULTANCY SERVICE LIMITED will share the information that you have authorized with the third parties or categories of specific third parties informed when collecting your consent.
(2) Sharing with our service providers: LIGHTHOUSE CONSULTANCY SERVICE LIMITED may also disclose your information to companies that provide services for us or on our behalf. These service providers include companies that offer IT services, such as our hosting provider or our email sending service provider, delivery services for our products, or that offer marketing activities on our behalf. These service providers may use your information solely for the purpose of providing services to you on behalf of LIGHTHOUSE CONSULTANCY SERVICE LIMITED.
(3) In fulfillment of a legal obligation, sharing in accordance with laws and regulations: LIGHTHOUSE CONSULTANCY SERVICE LIMITED, may share your information as required by laws and regulations, in order to resolve legal disputes, or as stipulated by the judicial or administrative authorities under the law.

LIGHTHOUSE CONSULTANCY SERVICE LIMITED will ensure the legality of any sharing of personal data through data processing clauses with the companies with which your personal data is shared, requiring them to comply with this privacy policy and take steps to appropriate security and confidentiality when processing personal data.

III. How LIGHTHOUSE CONSULTANCY SERVICE LIMITED protects your personal data
LIGHTHOUSE CONSULTANCY SERVICE LIMITED attaches great importance to the security of your personal data and has adopted standard industry practices to protect your personal data and prevent unauthorized access, disclosure, use, modification , damage or loss of this information.
We have also taken the necessary precautions to preserve, through our host, the security and confidentiality of the data, and in particular to prevent it from being distorted, damaged or communicated to unauthorized persons.
LIGHTHOUSE CONSULTANCY SERVICE LIMITED also adopts the following organizational measures:
(1) We take reasonable and feasible measures to ensure that the personal data collected is minimal and relevant as necessary, having regard to the purposes for which it is processed.
(2) We retain your personal data for the period strictly necessary for the purpose of the processing, unless retention of your data is required or permitted by law. For example, we keep data related to the execution of your orders for the period required by law for the retention of accounting records, namely a maximum of 10 years from the financial year concerned.
(3) We deploy access control mechanisms to ensure that only authorized personnel can access your personal data.
In the event of a personal data breach, LIGHTHOUSE CONSULTANCY SERVICE LIMITED will comply with the legal and regulatory requirements applicable to the notification of personal data breaches to the relevant supervisory authorities and/or data subjects.

IV. Where LIGHTHOUSE CONSULTANCY SERVICE LIMITED hosts and transfers your personal data
Your personal data will be hosted within the hosting infrastructures of our host, Wix Studio, located in Israel.
Certain third parties to whom we communicate your personal data are located in countries outside the European Union, and in particular in China.

When the products available for sale on the website are delivered by resources located in countries outside the European Union, we will be required to transfer your personal data to these countries. It may also happen that service providers access your data on our behalf in order to provide us with a specific service and are located in countries outside the European Union.

Where such transfers exist, we ensure that these transfers of personal data are regulated in accordance with the applicable regulations in order to ensure an adequate level of data protection, either by an adequacy decision of the European Commission, or through legal instruments such as data transfer contracts incorporating the Standard Contractual Clauses of the European Commission.

For any queries regarding recipients and data transfers that we carry out outside the European Union, please contact us at the addresses indicated in the “How to contact us” section below.

V. How you can manage your rights relating to your personal data
You have a right of access, rectification, erasure, limitation, opposition concerning the processing of your personal data as well as the right to define directives relating to the fate of your data after your death and the right to the portability of your personal data.

The Privacy Commissioner for Personal Data (PCPD) defines personal data as “any information relating to an identified or identifiable natural person. But because they concern people, they must retain control over them.”

You also have a right of appeal to the Privacy Commissioner for Personal Data (PCPD) for Hong Kong and to a competent supervisory authority for any other Member State depending on your habitual residence, your place of work or the place where the violation of your rights has been committed if you consider that the processing of your data does not comply with the applicable texts. This recourse may be exercised without prejudice to any other recourse before an administrative or judicial court which also constitutes a right available to you.

You can contact us at any time at the addresses indicated in the “How to contact us” section below in order to exercise your rights regarding personal data under the conditions set by the applicable regulations. You must indicate which right you intend to exercise as well as all the necessary details so that we can respond to your request.

These rights are exercised under the conditions set by the applicable regulations.
- The right of access means that you can ask us at any time to tell you whether we are processing personal data concerning you and, if so, to tell you what personal data are concerned as well as the characteristics of the processing(s) carried out .
- The right to rectification means that you can ask us to rectify your personal data when it is inaccurate. You can also request that your personal data, if incomplete, be completed to the extent that this is relevant to the purpose of the processing in question.
- The right to erasure means that you can request to erase your personal data, particularly when:
(i) Their conservation is no longer necessary in view of the purposes for which they were collected;
(ii) Your personal data is processed on the basis of your consent, you wish to withdraw this consent, and there is no other legal basis capable of justifying the processing;
(iii) You have objected to the processing of your personal data and you therefore wish them to be erased;
(iv) Your personal data has been the subject of unlawful processing;
(v) Your personal data must be erased to comply with a legal obligation which is provided for either by European Union law or by French law.

- The right to limitation means that you can ask us to limit the processing of your personal data:
(i) When you contest the accuracy of your personal data for a period allowing us to verify the accuracy thereof;
(ii) When following processing established as non-compliant, you prefer limitation of processing to complete erasure of your personal data;
(iii) When we no longer need your personal data for the purposes of processing but they are still necessary for the establishment, exercise or defense of legal rights;
(iv) When you have objected to the processing of your personal data and you wish to limit the processing for the period allowing us to verify whether the legitimate reason you invoke is justified.
Restriction of processing means that the processing of your personal data will then only involve the storage of your corresponding personal data. We will then no longer carry out any further operations on the personal data in question.

- The right to object means that you can object to the processing of your personal data, when this processing is based on the pursuit of the legitimate interests of LIGHTHOUSE CONSULTANCY SERVICE LIMITED. The right to object is exercised subject to providing a legitimate reason relating to your particular situation. We will then cease the processing in question unless there are legitimate and compelling reasons justifying continuation in accordance with the applicable regulations.
- The right to define directives relating to the fate of your data after your death allows you to make known your instructions concerning the conservation, erasure and communication of your personal data after your death.
- The right to portability means that you can ask us, under the conditions set by applicable regulations, to receive your personal data in a structured, commonly used and machine-readable format, and to transmit them to you, or to ask us to transmit them directly to a third party of your choice when legally and technically possible.

When we process your personal data on the basis of your consent, you finally have the option to withdraw your consent at any time by contacting the addresses indicated in the 'How to contact us' section or by clicking on the unsubscribe link present in each of our communications.
However, the withdrawal of your consent does not call into question the validity of the processing carried out before this withdrawal.

VI. Updates to this privacy policy
LIGHTHOUSE CONSULTANCY SERVICE LIMITED reserves the right at any time to modify or update, in whole or in part, this confidentiality policy, due to the modification of the applicable regulations regarding the protection of personal data or the processing of data carried out.
Any substantial modification of the confidentiality policy will be notified to you by e-mail when you have provided us with a valid e-mail address and will be published on the website. We recommend that you regularly read this confidentiality policy in order to have complete knowledge of our commitments in terms of security and protection of your personal data.

VII. How to contact us
If you have any questions, comments or suggestions, please contact us by visiting the contact us page or submitting them to pauline@royalcaviarclub.com.
Or by post to 29/F, Singga Commercial Centre, 148 Connaught Rd W, Sai Ying Pun.
If you are not satisfied with the response provided by LIGHTHOUSE CONSULTANCY SERVICE LIMITED to a request to exercise rights in accordance with Article V above or you wish to report a breach of the applicable data protection regulations , you have the right to lodge a complaint with the Privacy Commissioner for Personal Data (PCPD) by post (PCPD - 12/F, Sunlight Tower, 248 Queen's Road East, Wanchai, Hong Kong) or on its website (www. pcpd.org.hk), or to the data protection authority of the country in which you usually reside or work.