PRIVACY POLICY
LUXEBEAUTE INTERNATIONAL ACADEMY INC
I. INTRODUCTION
At LUXEBEAUTE INTERNATIONAL ACADEMY INC, ("we", "us" or "our") we commit to the protection of data of the users ("you", "your" or "yours") obtained in the course of its business. We take the privacy of our users very seriously and urge all users to read our Privacy Policy carefully. By using our Website, using our Services or purchasing our Products, you agree and acknowledge to this Privacy Policy. This also means you consent to the processing of your data or information obtained from the usage of the Website. If you do not agree to or understand this Privacy Policy, you may simply cease or refrain from using the Website.
This privacy policy (hereinafter known as "Privacy Policy") provides crucial information about:
1. The type of data or information we collect
2. The manner of collection, storage, and usage of data or information
3. The purposes for which we collect and use data
4. How we share your data or information
5. How long we retain your data or information
6. Your rights concerning your data or information
7. Management of any modifications to this Privacy Policy
8. How to contact us in case you have any suggestions, concerns, or complaints
The foregoing information will be stated by this "Privacy Policy" incorporating the minimum standards provided by Republic Act No. 10173, also known as the "Data Privacy Act of 2012" (An Act Protecting Individual Personal Information In Information And Communications Systems In The Government And The Private Sector, Creating For This Purpose A National Privacy Commission And For Other Purposes) which took effect on September 8, 2012 (the "Act").
This Privacy Policy excludes personal information about the user obtained from other sources or sources outside of the use of this Website.
II. EFFECTIVE DATE
This Privacy Policy comes into force and effect on 28 August 2024.
III. DEFINITIONS:
Website: This Privacy Policy will be applicable to www.luxebeaute.net, which shall hereinafter be known and referred to as "Website".
Who we are: LUXEBEAUTE INTERNATIONAL ACADEMY INC, ("we", "us" or "our") use www.luxebeaute.net, and we collect, store, and use your data or information.
User: The user ("you", "your" or "yours") using this Website, which means you agree to the provisions of this Privacy Policy.
Parties: The parties to this Privacy Policy are the Personal Information Controller or "LUXEBEAUTE INTERNATIONAL ACADEMY INC" and the user.
Personal Information Controller: Refers to LUXEBEAUTE INTERNATIONAL ACADEMY INC or the one who is responsible for the control of the processing of your data or information.
Personal Information: Refers to and may be used interchangeably with your "data or information" that we obtain from your use of www.luxebeaute.net, which can directly or reasonably ascertain your identity.
Products: Refer to any goods or products that are offered for sale on www.luxebeaute.net.
Services: Refer to any services that are offered on www.luxebeaute.net.
IV. PERSONAL INFORMATION
The following are the types of personal information that will be collected from your use of the Website:
Types of personal information:
1. Identification Information
Full Name: To identify the user for account management and certification.
Date of Birth: For age verification to ensure eligibility for certain courses or promotions.
2. Contact Information
Email Address: For sending course-related communications, marketing emails, and notifications.
Phone Number: For urgent communications, support, and verification purposes.
Postal Address: Needed for shipping materials, certificates, or products related to courses.
3. Financial Information
Credit/Debit Card Details: For processing course fees or other payments.
Bank Account Information: Sometimes required for refunds or payments for services rendered.
Payment History: To maintain records of transactions for customer service and accounting purposes.
4. Educational and Professional Information
Educational Background: To tailor course recommendations and assess eligibility for advanced courses.
Professional Experience: Relevant in courses that require a certain level of professional expertise or for career advancement programs.
5. Technical Information
IP Address: For managing session information and improving site security.
Browser Type and Version: Helps optimize the website for better compatibility and performance on different browsers.
Device Information: Such as device type and operating system for optimizing the website’s display and functionality across devices.
6. Usage Data
Cookies and Similar Technologies: To understand user preferences, website navigation patterns, and to personalize content.
Login Data: Tracks user access to various parts of the website, helping to enhance user experience and security.
7. Interaction Information
Feedback and Survey Responses: Collected when users participate in feedback mechanisms to improve services.
Communication Records: Including emails and chat logs, which help in resolving user queries and maintaining high service standards.
8. Social Media Information
Social Media Handles and Profile Information: If users connect or interact with the website through social media platforms.
9. Sensitive Personal Information
Health Information: In specific contexts, such as if it’s relevant to participation in certain health or wellness courses.
Biometric Data: Rarely, but could be used for unique identification or security purposes, subject to stringent legal protections.
V. LEGITIMATE PURPOSE OF PROCESSING PERSONAL INFORMATION
Your personal information will be processed pursuant to the following purposes:
1. User Registration and Profile Management
Purpose: To create and manage user accounts, enabling users to enroll in courses, access materials, and receive updates.
Data Collected: Names, email addresses, phone numbers, and potentially addresses for mailing of course materials or certificates.
2. Course Enrollment and Administration
Purpose: To administer and manage courses, including tracking progress, issuing reminders, and granting certifications.
Data Collected: Educational background, payment information, and course preferences.
3. Customer Support and Communication
Purpose: To provide support, address inquiries, and resolve issues. Also, to communicate important information about courses, changes, and opportunities.
Data Collected: Contact details, communication history, and any other relevant information provided by the user during interactions with support staff.
4. Marketing and Promotions
Purpose: To inform users about promotions, new courses, and events that may be of interest.
Data Collected: Email addresses, purchase history, and user preferences.
5. Feedback and Surveys
Purpose: To gather feedback to improve courses and services, and to develop new offerings based on user needs.
Data Collected: Responses to surveys and feedback forms.
6. Analytics and Performance Monitoring
Purpose: To understand how users interact with the website, which helps improve user experience, identify preferences, and detect areas for enhancement.
Data Collected: Browsing history, device information, and interaction data through cookies and similar technologies.
7. Legal Compliance
Purpose: To comply with legal obligations, such as tax laws, anti-fraud measures, and other regulatory requirements.
Data Collected: As required by law, which could include a range of personal data depending on the specific legal requirement.
8. Security Measures
Purpose: To ensure the integrity and security of the website and its users' data against unauthorized access, breaches, and fraud.
Data Collected: Log data, access times, and security-related events.
Our main purpose for using your personal information is to improve your experience on our Website and provide you with the services and/or information you have requested. Additionally, we may use information that is not considered personal information to gain broad insights into our customer base, which may be used for market research or marketing efforts. This information might include interests based on your cookies, among other things.
Personal Information may also be processed for the following purposes:
1. Registration of your account for the use of various features of our Website
2. Communication of user account, and marketing information and if any
3. Enhancement of user experience
4. Billing or credit information or fulfilling transactions if any
5. Sharing of your data or information to affiliate companies
6. Providing customer service
7. Aggregation or combination of Data (Analytics)
8. Automated decision-making
VI. COLLECTION OF DATA OR INFORMATION
Depending on your usage of our Website, your personal information may be collected from you. Collection may be done in any of the following manners:
A. Registration of users: You, as a user of the Website, may register or create an account to access more features of the Website. By registering, we will collect or obtain the following personal information from you:
Personal Identification Information
Full Name: To identify the user for communication and certification purposes.
Date of Birth: Used for age verification to ensure eligibility for certain courses.
Gender: Optional, but can be used for demographic analysis and personalization.
Contact Information
Email Address: Essential for account verification, password resets, course notifications, and marketing communications if consented to.
Phone Number: For additional contact purposes, which may include urgent updates or SMS notifications.
Postal Address: Necessary if physical materials or certificates need to be mailed.
Account Security Information
Username and Password: Used for creating and accessing the user account.
Security Questions and Answers: Optional, to enhance account security and assist in account recovery.
Professional and Educational Background
Educational Qualifications: Information about previous education that may be relevant to course eligibility or placement.
Professional Experience: Details about work history, especially if courses are tailored for professionals with certain levels of experience.
Payment Information
Credit/Debit Card Details: Necessary for processing payments for courses or services. This might be handled via a secure third-party payment processor.
Billing Address: Used for payment verification and invoicing.
Preferences and Interests
Course Preferences: To help guide users to courses that best suit their interests or career goals.
Communication Preferences: Choices regarding how the user wishes to receive updates, marketing materials, and other communications.
Consent Confirmations
Privacy Policy and Terms of Service Agreement: Confirmation that the user has read and agrees to the website’s privacy policy and terms of service.
Marketing Consent: Explicit opt-in choices for receiving promotional emails or other marketing materials.
Personal information may be collected from you after registration in order to:
a. Allow our officers or representatives to interact with you in any manner such as by messaging or email.
b. Notify you via email or SMS about general information about your use of our Website.
c. Allow you to leave comments on our Website's content including but not limited to photos, videos, text content, and forms.
The completion of your registration means you provide your consent to allow us to collect, store, use, or disclose your personal information according to the provisions of this Privacy Policy.
B. Passive usage: Data may be collected from you passively through "Cookies", even if you do not undergo the registration process. Passive data collection may include location information, IP address information, or browser data such as session information.
C. Data sharing with affiliate companies: We may share your personal information, or information that tends to show your identity with any of our affiliate companies or trusted organizations for us to provide a better user experienceand offer you the best products and services suited to your needs.
This is however subject to the prior approval of such related entity or trusted organization of our Privacy Policy, and an agreement to comply with the same standards of how we protect your data or information.
The affiliate companies or trusted organizations to which your personal information will be shared are the following:
Xendit Philippines
LuxeBeaute Solutions Inc
"We may share your personal information with our affiliate companies and related organizations to enhance our services, provide you with tailored offers, or for operational purposes. This sharing is governed by strict privacy protections and is in line with our commitment to safeguard your privacy. We ensure that all affiliates adhere to similar privacy standards as ours and only share the necessary information required to deliver improved services. You will be notified and your consent will be obtained when necessary, particularly where your information is used for purposes not directly related to the services you have engaged us for."
D. Billing Information: For purposes of purchasing products or services offered on our Website, we may ask you to provide certain credit information, billing address information, and additional specific information for us to be able to charge you accordingly. This information may be stored for the following period of time: At LuxeBeaute International Academy Inc., we prioritize the security and privacy of your personal and payment information. To ensure the highest level of security, we do not store any billing information on our website. Instead, we have partnered with Xendit, a trusted third-party payment gateway, to handle all payment processing. Why Use Xendit? Enhanced Security: Xendit specializes in secure payment processing and complies with the latest security standards to protect your information. Reduced Risk: By using Xendit, we ensure that sensitive payment details are never stored on our servers, minimizing the risk of data breaches. Efficiency: Xendit provides a smooth and efficient payment process, allowing you to make transactions quickly and safely without concerns about the security of your payment information. Privacy and Data Protection Xendit processes all payment transactions under strict privacy and security protocols. For more details about how Xendit handles your personal information, you can visit their privacy policy on their website. We are committed to transparency and the protection of your data. If you have any questions regarding our use of Xendit or how we handle your information, please do not hesitate to contact us. The billing information you provide shall only be used for facilitating your transactions with us.
E. User Experience: We may ask for your suggestions on how we can improve our Website. This may be done by means of surveys, questions, or ratings asked, which may be conducted from time to time.
F. We have an automated decision-making system that may decide and take actions for you. This means that your data or information will be used to run processes for you automatically which is conducted by software programming or data management systems. Thus, this decision-making process is not done by a human.
At each instance with which you may be subjected to an automated decision-making system, we will notify you that a decision or action was made in such manner. Pursuant to your right to access, you can request for a review of such decision or action. Any automated decision-making process will take place in the following manner:
1. Data Collection
Source: Automated systems collect data directly from user interactions with the website (e.g., registration, course selection, browsing behavior) and from other sources like social media or third-party data providers.
Types of Data: This includes personal details, preferences, behavioral data, and possibly engagement metrics.
2. Data Processing and Analysis
Integration: Data from various sources is aggregated and integrated into a central system.
Preprocessing: Data is cleaned and formatted to ensure it is accurate and suitable for analysis. This might involve removing errors or incomplete data entries.
Analysis: Advanced algorithms or machine learning models analyze the data to identify patterns, trends, or predictive insights.
3. Decision Rules Setup
Criteria Definition: Decision criteria are defined based on the business objectives. For example, in a course recommendation system, criteria might include user interests based on past courses, similarity to other users, or trending topics.
Algorithm Training: Machine learning models are trained on historical data to learn how to make predictions or decisions that align with defined goals.
4. Automated Decision Making
Execution: The trained algorithms apply the decision rules to new data to make automatic decisions. For instance, approving a registration, recommending courses, or personalizing marketing messages.
Outcomes: The system outputs decisions that are then acted upon automatically. This might involve sending a personalized course list, approving a user’s registration, or placing users in specific marketing segments.
5. Post-Decision Actions
Notification: Users are typically notified of decisions that affect them, particularly in cases of significant decisions like credit approvals or eligibility for special programs.
Feedback Loop: User responses or behaviors following the decision are monitored to refine and improve the decision-making algorithms.
6. Review and Human Oversight
Human Review: Important decisions, particularly those with significant consequences for users, are often structured to include the possibility of human review upon request.
Adjustments: Continuous feedback and performance metrics are used to adjust algorithms and decision criteria to improve accuracy and fairness.
7. Compliance and Ethics
Regulatory Compliance: Ensure all automated decision-making processes comply with relevant data protection laws, such as GDPR, which includes rights to explainability, the right to opt-out, and the right to human intervention.
Ethical Standards: Maintaining ethical standards to avoid biases and ensure fairness in automated decisions, especially in diverse user populations.
G. Combination of Data or Information: We may aggregate or combine some of your personal information in order to provide you with the best user experienceand offer you the products and services that are best suited to your needs or usage patterns.This combined or aggregated information may also be shared with affiliate companies or trusted organizations in accordance with this Privacy Policy.
VII. PERSONAL INFORMATION WE RECEIVE AUTOMATICALLY (COOKIES)
We may gather or collect information from you using automated technology that captures data about your browsing behavior and history, and the data or information that you willingly provide to us, such as details shared during the registration process or at other points when using the Website. For instance, we may use cookies to improve or enhance your browsing experience by storing information that may pertain to your preferences, the device type you used, or previous choices you made on the site. Cookies, which are small text files, allow us to modify the Website according to your expectations and provide a more customized browsing experience. The information in a cookie is limited and can only be read by the web server that issued it. It is not an executable code and is virus-free. Cookies do not save or transmit any personal information. If cookies are disabled, the functions of our Website may be limited. To proceed without changing your cookie settings, simply continue to use our Website. The following are the type of cookies that we may receive from you:
A. HTML cookies or technical cookies are utilized to allow you to access or go through different pages of the Website. They are needed to transmit communications using the network and provide the services you request. The utilization of these cookies also allows for the safe and efficient use of our Website.
B. Cookies may also be utilized for purposes of analytics or statistics, or to collect aggregated or combined data or information.
C. Temporary session cookies are those which are destroyed or deleted after a browsing session and are used to identify you and allow you to not log in repeatedly after each browsing session so long as your browser is not closed.
D. Permanent cookies are those which remain for a longer period, while these function the same as temporary cookies in that they are used to identify you and allow you to not log in repeatedly after each browsing session, they remain on your device even after your browser is closed.
E. Profiling cookies are utilized to establish user profiles and send you marketing or advertising communications according to your browsing behavior and history.
F. Third-party cookies are cookies transmitted by a third party to your device. These are often permanent cookies which are used to determine your browsing behavior and history for purposes of providing customized browsing and a better user experience.
G.Third-party profiling cookies are utilized to establish your profile to send you marketing or advertising communications according to your browsing behavior and history.
H. Third-party analytical cookies may also be utilized by sending them from outside third parties, to our Website. This will also enable us to determine browsing behavior and history on our Website to monitor performance and provide a better user experience.
You provide your specific consent when these types of cookies are used to enable you to have the best experience on our Website.
VIII. CRITERIA FOR LAWFUL PROCESSING OF PERSONAL INFORMATION
In accordance with the specified purposes of using your data or information, the following are the criteria or legal basis for processing your information:
A. You give us your consent before we collect and process your personal information.
B. Processing your personal information involves the performance of an obligation under a contract to which you are a party, including the act of entering into a contractual obligation.
C. Processing your personal information is required for us to comply with a legal obligation.
D. Processing your personal information is necessary to protect vitally important interests, including your life and health, or those of another.
E. Processing your personal information is necessary to respond to a national emergency, or to comply with the requirements of public order and safety, as prescribed by law.
F. Processing your personal information is necessary to fulfill the constitutional or statutory mandate of a public authority.
G. Processing your personal information is necessary to ensure our legitimate interests or the legitimate interests of a third party (except when such interests are overridden by your fundamental and constitutional rights.) Details of the legitimate interests referred to herein will be provided if this is the basis or criterion by which your personal information is processed.
Generally, we will process your personal information based on the specified purposes in this Privacy Policy mainly where:
A. We obtain your consent explicitly each time we process your personal information based on the purposes specified in this Privacy Policy.
B. It is required in order to perform a contractual obligation to which you are a party, including the act of entering into such contractual obligation with you.
C. We are required to comply with a legal obligation.
D. It is necessary to protect vitally important interests, including your life and health, or those of another.
E. It is necessary to pursue our legitimate interests or those of another after we ensure that your fundamental and constitutional rights are protected.
F. It is necessary for the fulfillment of the constitutional or statutory mandate of a public authority.
G. It is necessary to respond to national emergency or to comply with the requirements of public order and safety, as prescribed by law.
IX. THIRD-PARTY SERVICE PROVIDERS
We may share your information with third-party service providers, and vice versa, to help improve your experience on our Website. This includes the following:
A. Non-sale of Data: Your personal information will not be sold to third parties without first obtaining your specific consent.
B. Hosting: We may use the services of third-party service providers to host our Website which will also allow such providers to access your personal information.
C. Storage: We may use the services of third-party service providers for web or cloud storage to assist us with storing your information.
D. Tracking: We may use the services of third-party service providers to track usage data and determine user behavior and patterns of usage to improve the Website and your experience within it.
E. Advertising: We may allow third-party service providers to advertise on our Website and use cookies for marketing and advertising purposes.
F. Logistics: We may use third-party service providers to fulfill orders in relation to products and services offered on our Website.
G. Social Media API: Our Website uses the API (Application Programming Interface) of social networks, in order to allow integration of the functionalities of such social networks into your use of the Website. This integration allows for easy sharing of your data or information from our Website to such social networks and vice versa. Cookies are set if you voluntarily use the services of such social networks within our Website, thus it means that you consent to the use of cookies. The handling or processing of your data or information is governed by the respective privacy policies of such social networks. You may read the privacy policies in their respective websites.
X. LENGTH OF RETENTION OF PERSONAL INFORMATION
Your data or information will be retained by us for a period of time, not more than what is required to fulfill the purposes as specified in this privacy policy.
The manner by which we will retain your data or information is described as follows:
"LuxeBeaute International Academy Inc. retains personal data only for as long as necessary to fulfill the purposes for which it was collected, including any legal, accounting, or reporting requirements. For example, information related to your enrollment and academic achievements is retained indefinitely to allow for the verification of educational credentials. Financial records are retained for 7 years in compliance with tax laws. If you decide to close your account with us, we will delete or anonymize your personal data within [specified time period] unless there is a legal reason to retain it longer."
After the lapse of the period as stated in the previous paragraph, your information shall be destroyed, deleted, or anonymized.
XI. SECURITY MEASURES
We will make sure that your data or information is safe and secure through the measures we have in place for you. We have adopted organizational, physical, and technical security measures to maintain the protection of your data and information.
Organizational Security Measures:
Only the staff of the Website who undergo the privacy training shall be allowed to handle data; There will be a strict code of conduct for employees in handling user data or information.
Physical Security Measures:
The papers containing user information and data shall be destroyed using a shredder after the user requests the deletion of their data; The screens of devices used by a staff shall be protected by a privacy film to prevent others from viewing the data on such screens.
Technical Security Measures:
The staff of the Website uses virtual private networks for their work devices to prevent access from outside sources and Website apart from what is essential to the duties of such staff. We will conduct regular testing and assessment to determine whether there are vulnerabilities in the Website security.
XII. LOCATION OR SCOPE AND CROSS-BORDER TRANSFER OF DATA
Your data or information may be processed not only within the Philippines but also in other countries and with third parties therein and is subject to the requirements of the Data Privacy Act of 2012 and the relevant law or regulation applicable such as the EU's General Data Protection Regulation or the GDPR.
XIII. RIGHTS OF THE USER
The following are your rights in relation to your data or information handled by us. These rights are those laid down by the Data Privacy Act of 2012:
A. Right to be informed: You have the right to be informed whether data or information pertaining to you shall be, are being, or have been processed, including the existence of automated decision-making and profiling.
B. Right to object: You have the right to object to the processing of your data or information, including processing for direct marketing, automated processing, or profiling.
When you object or withhold your consent, we shall no longer process the personal data, unless:
a. The data or information is needed pursuant to a subpoena;
b. The collection and processing are for obvious purposes, including, when it is necessary for the performance of or in relation to a contract or service to which you are a party, or when necessary or desirable in the context of an employer-employee relationship between the collector and the data subject; or
c. The information is being collected and processed as a result of a legal obligation.
C. Right to access: You have the right to reasonable access to, upon demand, the following:
a. Contents of your data or information that were processed;
b. Sources from which your data or information were obtained;
c. Names and addresses of recipients of your data or information;
d. Manner by which such data were processed;
e. Reasons for the disclosure of your data or information to recipients, if any;
f. Information on automated processes where the data will, or is likely to, be made as the sole basis for any decision that significantly affects or will affect you;
g. Date when your personal information concerning you, was last accessed and modified; and
h. Our designation, name or identity, and address.
D. Right to rectification: You have the right to dispute the inaccuracy or error in your data or information and have us correct it immediately and accordingly unless the request is vexatious or otherwise unreasonable.
E. Right to erasure or blocking: You have the right to suspend, withdraw or order the blocking, removal, or destruction of your data or information from our systems.
F. Right to data portability: You have the right to electronically move, copy or transfer your data or information without cost for whatever use you require.
G. Right to damages and to file a complaint: You have the right to file a case and/or be indemnified for any damages sustained due to such inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of your data or information, taking into account any violation of your rights as a data subject.
XIV. REVISION AND UPDATE OF PRIVACY POLICY
We may update and revise this Privacy Policy from time to time and will notify you of any changes. Our Website was last published and updated on 28 August 2024.
The notice of revision may be made in the following manners:
By email or sms if you have1. Timing of Notification
Advance Notice: Provide users with advance notice before any changes take effect. This gives users sufficient time to review the changes and make informed decisions about their continued use of the website.
2. Methods of Notification
Email: Send an email to all registered users outlining the key changes and the effective date of the new policy. Include a link to the full updated Privacy Policy.
Website Notifications: Place a prominent notification on the website's homepage or a dedicated user dashboard. This can include a brief summary of the changes and a direct link to the detailed updated Privacy Policy.
In-App Notifications: If applicable, send notifications through any associated mobile or web applications, alerting users to the changes with direct links to the updated policy.
Pop-Up Messages: Implement a pop-up message that appears when users first log in or visit the site after the changes have been made, ensuring visibility.
3. Content of Notification
Summary of Changes: Provide a clear summary of what changes have been made to the Privacy Policy. Highlight significant changes, especially those related to how personal data is collected, used, and shared.
Reason for Changes: Explain why these changes are being made. This could be due to new legal requirements, changes in business practices, or improvements in data protection and privacy.
Impact on Users: Describe how the changes may affect the way users' information is handled.
Action Required: If users need to take any actions, such as giving new consents or adjusting their privacy settings, clearly state this requirement.
4. User Rights and Options
Review and Consent: Encourage users to review the updated policy thoroughly and to continue using the website only if they agree to the new terms.
Opt-Out Options: Inform users of their rights to opt out of certain uses of their data if applicable. Provide easy-to-follow instructions on how to do this.
Contact Information: Offer a way for users to contact LuxeBeaute International Academy Inc. if they have questions or concerns about the changes.
5. Documenting User Consent
Record Keeping: Keep records of notifications sent to users and any consents obtained, ensuring compliance with legal obligations under data protection laws.
XV. CONTACT
The Party responsible for the processing of your Data or Information is: LUXEBEAUTE INTERNATIONAL ACADEMY INC. The Personal lnformation Controller ("Us") may be contacted using the following information:
Business Name: LuxeBeaute International Academy Inc.
Phone Number: 02-7149 5188
Email Address: pmuinternationalacademy@luxebeaute.net
Physical Address: 257 RMR Centre Doña Soledad Avenue, Don Bosco Extension Parañaque City, 1700
