Privacy policy

Privacy and Cookie Policy

Last updated: 5 July 2026

1. About this Policy

ICT Business Advice LTD, trading as Luxbelle, respects your privacy and is committed to protecting your personal data.

This Privacy and Cookie Policy explains how we collect, use, store and share your personal data when you:

  • visit luxbelle.co.uk;
  • create an account;
  • place or attempt to place an order;
  • contact us;
  • subscribe to marketing communications; or
  • otherwise interact with Luxbelle.

It also explains your rights and how we use cookies and similar technologies.

For the purposes of applicable data protection law, ICT Business Advice LTD is the controller responsible for the personal data described in this Policy.

2. Information About Us

Luxbelle is operated by:

ICT Business Advice LTD
Registered in England and Wales
Company number: 11152300
Email: luxbelle22@gmail.com

3. The Laws That Apply

We process personal data in accordance with applicable UK data protection and privacy legislation, including:

  • the UK General Data Protection Regulation;
  • the Data Protection Act 2018, as amended;
  • the Data (Use and Access) Act 2025; and
  • the Privacy and Electronic Communications Regulations 2003.

Where the EU General Data Protection Regulation applies to our processing, we will also comply with its applicable requirements.

4. What Is Personal Data?

Personal data is information relating to an identified or identifiable individual.

It includes obvious information such as your name, address and email address, as well as less obvious information such as your IP address, device identifiers, online activity and cookie identifiers.

We do not intentionally collect special-category personal data, such as information about health, religion, ethnicity or sexual orientation.

Our Site and online checkout are intended for people aged 18 or over. We do not knowingly collect personal data from children.

5. Personal Data We Collect

Depending on how you use our Site, we may collect the following information.

Identity and contact information

This may include:

  • your name;
  • billing address;
  • delivery address;
  • email address;
  • telephone number; and
  • account details, where you create an account.

Order and transaction information

This may include:

  • the products you purchase or place in your basket;
  • order values;
  • order history;
  • payment status;
  • delivery and tracking information;
  • returns, refunds and exchanges; and
  • discount codes or promotional offers used.

Payments are processed by Shopify and the payment providers made available at checkout. We do not normally receive or store your complete payment-card number.

Customer-service information

This includes information you provide when you:

  • contact us by email or through the Site;
  • ask a question about a product;
  • request support;
  • submit a return or refund request;
  • make a complaint; or
  • exercise a data-protection right.

Marketing information

This may include:

  • whether you have subscribed to marketing;
  • your marketing preferences;
  • your interaction with emails or advertisements;
  • the advertisements that directed you to our Site; and
  • whether an advertisement contributed to a visit, checkout or purchase.

Technical and usage information

This may include:

  • IP address;
  • browser type and version;
  • device type;
  • operating system;
  • approximate location;
  • referring website or advertising source;
  • pages and products viewed;
  • searches performed;
  • links or buttons clicked;
  • session duration;
  • scrolling and navigation activity;
  • checkout and purchase events;
  • error and performance information; and
  • cookie, advertising and device identifiers.

Information obtained from third parties

We may receive information from:

  • Shopify;
  • payment providers;
  • delivery and fulfilment providers;
  • Meta;
  • Google;
  • Microsoft;
  • fraud-prevention providers;
  • advertising partners; and
  • other service providers used to operate the Site.

6. How We Use Your Personal Data

We only use personal data where we have a lawful basis for doing so.

Processing and fulfilling orders

We use identity, contact, order and transaction information to:

  • process your order;
  • take or confirm payment;
  • arrange fulfilment and delivery;
  • provide order confirmations and updates;
  • manage cancellations, returns, refunds and exchanges; and
  • respond to questions concerning your purchase.

Our lawful basis is the performance of our contract with you and taking steps at your request before entering into a contract.

Operating the Site and customer accounts

We use account, technical and usage information to:

  • provide the Site and its features;
  • remember the contents of your basket;
  • manage customer accounts;
  • maintain website security;
  • prevent unauthorised access;
  • diagnose technical problems; and
  • ensure that pages and checkout functions operate correctly.

Our lawful bases are performing our contract with you and our legitimate interests in operating a secure and functional ecommerce business.

Customer service and communications

We use identity, contact, order and communication information to:

  • answer questions;
  • provide customer support;
  • investigate complaints;
  • resolve delivery or payment issues; and
  • communicate important information concerning an order or account.

Our lawful bases are performing our contract with you and our legitimate interests in providing effective customer service and maintaining our relationship with customers.

Fraud prevention and security

We may use identity, payment, transaction, device and technical information to:

  • detect potentially fraudulent transactions;
  • protect our customers and business;
  • maintain the security of the Site;
  • enforce our terms; and
  • establish, exercise or defend legal claims.

Our lawful bases are our legitimate interests in preventing fraud and protecting our business, customers and systems, and compliance with legal obligations where applicable.

Analytics and website improvement

Where required, and subject to your cookie choices, we use Shopify analytics, Google Analytics and Microsoft Clarity to understand:

  • how visitors find and use the Site;
  • which pages and products receive attention;
  • where visitors encounter difficulties;
  • whether pages load and operate correctly;
  • how visitors navigate between pages;
  • the performance of marketing campaigns; and
  • how we can improve website usability, operation, performance and speed.

Our lawful basis for optional analytics cookies and similar technologies is your consent.

We may also use limited technical information that is strictly necessary to operate, secure and diagnose the Site. Our lawful basis for that processing is our legitimate interests in maintaining a secure and functional website.

Advertising and conversion measurement

Where you consent to marketing and advertising technologies, we use Meta Pixel and Meta Conversions API to:

  • measure visits, checkouts and purchases generated by advertisements;
  • understand the effectiveness of our advertising;
  • reduce duplicate conversion reporting;
  • create or measure advertising audiences;
  • show more relevant advertisements; and
  • improve how we allocate our marketing budget.

Depending on our configuration and your consent choices, information sent to Meta may include page activity, purchase events, browser or device information, IP address, cookie identifiers and contact identifiers that have been encrypted or hashed before transmission.

Our lawful basis for the use of optional advertising cookies, pixels and related tracking technologies is your consent.

Marketing communications

Where you have subscribed or where otherwise permitted by law, we may use your name, email address, purchase history and marketing preferences to send information about Luxbelle products, offers and promotions.

Where permitted by the Privacy and Electronic Communications Regulations, we may send existing customers marketing concerning products similar to those previously purchased or considered. Every marketing email will provide a way to unsubscribe.

You may withdraw your consent or unsubscribe at any time by:

Withdrawing consent does not affect the lawfulness of processing carried out before it was withdrawn.

Legal and regulatory obligations

We may use and retain personal data to:

  • maintain accounting and tax records;
  • respond to lawful requests;
  • comply with court orders or legal obligations;
  • protect our legal rights; and
  • cooperate with regulators, law-enforcement bodies or public authorities.

Our lawful basis is compliance with our legal obligations and, where applicable, our legitimate interests in protecting our legal rights.

7. Cookies and Similar Technologies

Cookies are small files stored on your browser or device. Similar technologies include pixels, tags, scripts, local storage and server-side conversion tools.

We use the following categories.

Strictly necessary technologies

These are required for the Site to function and may be used to:

  • operate the shopping basket and checkout;
  • process payments;
  • remember privacy choices;
  • maintain account sessions;
  • prevent fraud;
  • balance website traffic; and
  • protect the Site.

These technologies do not require consent where they are strictly necessary to provide a service you have requested.

Blocking them through your browser may prevent parts of the Site from functioning correctly.

Functional technologies

These may remember preferences and provide enhanced website features.

Where these technologies are not strictly necessary, we will use them only in accordance with your consent choices.

Analytics technologies

Subject to your consent, we use analytics technologies to measure traffic and understand how visitors use the Site.

Our analytics providers include:

Shopify Analytics
Used to understand store visits, traffic sources, sessions, customer journeys, product performance and purchases.

Google Analytics 4
Used to measure website usage, sessions, approximate location, browser and device information, page interactions and ecommerce events.

Microsoft Clarity
Used to understand how visitors interact with the Site through information such as clicks, scrolling, navigation patterns, heatmaps and session recordings. This helps us identify technical problems and areas where the shopping experience could be improved.

We do not intentionally use Microsoft Clarity to collect payment-card details or sensitive information entered into forms.

Advertising technologies

Subject to your consent, we use:

Meta Pixel
A browser-based technology that measures visits, product views, checkouts, purchases and other interactions connected with Meta advertising.

Meta Conversions API
A server-side technology that sends selected website or order events to Meta to measure advertising performance and improve conversion reporting.

Meta may use information received through these services in accordance with its own privacy terms.

8. Managing Your Cookie Choices

When you first visit the Site, Shopify’s cookie banner will provide options to accept, reject or manage optional cookies and similar technologies.

Strictly necessary technologies may operate without consent. Optional analytics and advertising technologies should operate only in accordance with your choices.

You can change or withdraw your choices at any time using the Cookie Preferences controls available on the Site.

You can also block or delete cookies using your browser settings. Doing so may affect website features, saved preferences, account login, basket contents or checkout operation.

Exact cookie names and lifespans may change when Shopify or our service providers update their services. Current information and available controls may be shown through our cookie-preference tool.

9. Automated Processing

We do not ourselves make decisions about you based solely on automated processing where those decisions produce legal or similarly significant effects.

Shopify, payment providers and fraud-prevention providers may use automated tools to assess transactions, detect fraud or protect payment systems. Their use of personal data is also governed by their respective privacy notices and contractual obligations.

10. Compatible Further Use

We normally use personal data only for the purposes for which it was collected.

If we need to use it for another purpose, we will consider whether the new purpose is compatible with the original purpose, taking into account:

  • the connection between the purposes;
  • the context in which the information was collected;
  • the nature of the information;
  • the possible consequences for you; and
  • the safeguards available.

Where the new purpose is not compatible and no other lawful basis applies, we will seek consent or provide appropriate information before proceeding.

We may process personal data without prior notice where the law requires or permits us to do so.

11. How Long We Keep Personal Data

We keep personal data only for as long as reasonably necessary for the purposes described in this Policy.

The following periods normally apply:

  • Order, transaction, tax and accounting records: up to six years from the end of the relevant financial year, or longer where required by law, a dispute, investigation or legal claim.
  • Customer account information: while the account remains active and for a reasonable period afterwards, unless earlier deletion is appropriate.
  • Customer-service correspondence: normally for up to 24 months after the matter is resolved, unless it relates to an order, dispute or legal obligation requiring longer retention.
  • Returns, refunds and complaints: for as long as necessary to resolve the matter and establish, exercise or defend legal claims.
  • Marketing information: until you unsubscribe, withdraw consent or the information is no longer needed. We may retain limited suppression information to ensure that we respect your opt-out.
  • Analytics and advertising information: according to our configured retention settings, consent choices and the relevant provider’s retention rules, and only for as long as needed for analytics, security and marketing measurement.

At the end of the applicable period, information will be deleted, anonymised or retained securely where continued retention is legally required.

12. How We Share Personal Data

We may share personal data with carefully selected third parties where necessary to operate Luxbelle.

These may include:

Shopify

Shopify provides our ecommerce platform, website hosting, checkout, order-management, analytics, fraud-prevention and related services.

Payment providers

Payment providers process payments, refunds and fraud checks. They may process your information as independent controllers or as service providers, depending on the service.

Fulfilment and delivery providers

We share the information required to prepare, dispatch, track and deliver your order. This can include your name, delivery address, telephone number, email address, order contents and tracking information.

Some fulfilment providers may be located outside the United Kingdom.

Analytics and advertising providers

Subject to your consent choices, we may share website, device, marketing and conversion information with:

  • Meta;
  • Google;
  • Microsoft; and
  • Shopify’s analytics and marketing services.

Professional and technical service providers

We may share information with:

  • website and application providers;
  • customer-support systems;
  • IT and security providers;
  • accountants;
  • legal advisers;
  • insurers; and
  • other professional advisers.

Public authorities and legal recipients

We may disclose personal data where required to:

  • comply with the law;
  • respond to a court order or lawful request;
  • prevent or investigate fraud;
  • protect our rights or the rights of others; or
  • establish, exercise or defend legal claims.

Business transfers

If all or part of our business is sold, reorganised, transferred or merged, personal data may be disclosed to potential purchasers, advisers or the new owner, subject to appropriate confidentiality and data-protection safeguards.

We do not sell personal data in the ordinary meaning of selling customer lists for money.

13. International Data Transfers

Some of our service, technology, payment, advertising, fulfilment and delivery providers may process personal data outside the United Kingdom.

This may include processing in the European Economic Area, United States, Canada, China or other countries in which our providers operate.

Where personal data is transferred internationally, we take steps intended to ensure that an appropriate level of protection applies. Depending on the destination and recipient, these measures may include:

  • UK adequacy regulations;
  • the UK International Data Transfer Agreement;
  • the UK Addendum to approved standard contractual clauses;
  • appropriate contractual protections;
  • recognised certification or transfer frameworks; and
  • additional technical or organisational safeguards where required.

Where EU data-protection law applies, transfers may also rely on an EU adequacy decision, EU standard contractual clauses or another lawful transfer mechanism.

14. Data Security

We use reasonable technical and organisational measures designed to protect personal data against accidental or unlawful loss, alteration, disclosure, destruction or unauthorised access.

These measures may include:

  • use of established ecommerce and payment providers;
  • encrypted connections;
  • restricted access to customer and order information;
  • account authentication and access controls;
  • confidentiality obligations;
  • fraud and security monitoring;
  • software and system maintenance; and
  • procedures for responding to suspected personal-data breaches.

No internet transmission or storage system is completely secure. We therefore cannot guarantee absolute security, but we will take appropriate steps where a security incident occurs.

15. Your Data-Protection Rights

Depending on the circumstances and the law that applies, you may have the right to:

  • be informed about how we use your personal data;
  • request access to personal data we hold about you;
  • request correction of inaccurate or incomplete information;
  • request deletion of personal data;
  • request restriction of processing;
  • object to certain processing based on legitimate interests;
  • object to direct marketing at any time;
  • withdraw consent at any time;
  • receive certain information in a portable format; and
  • raise concerns or make a complaint.

These rights are not absolute. We may need to retain or continue processing certain information where the law permits or requires it.

We may ask for information reasonably necessary to confirm your identity before responding to a request. We will not request more information than is necessary for that purpose.

16. Accessing Your Personal Data

You may request confirmation of whether we hold personal data about you and ask for a copy. This is known as a subject access request.

When responding, we will carry out reasonable and proportionate searches for information covered by the request.

Requests can be sent to:

luxbelle22@gmail.com

There is normally no fee. We may charge a reasonable fee or refuse to act where a request is manifestly unfounded or excessive, as permitted by law.

We will respond without undue delay and normally within one month. Where a request is particularly complex or numerous, the law may allow additional time. We will tell you where an extension applies.

17. Data-Protection Complaints

You can complain about how we have used your personal data by emailing:

luxbelle22@gmail.com

Please include sufficient information for us to understand and investigate your concern.

We will:

  • acknowledge a data-protection complaint within 30 days;
  • take appropriate steps to investigate it;
  • keep you reasonably informed; and
  • provide an outcome without undue delay.

You also have the right to complain to the UK Information Commissioner’s Office.

You may wish to contact us first so that we have an opportunity to resolve the matter, but you are not required to do so.

Where the EU GDPR applies, you may also have the right to complain to the relevant supervisory authority in the country where you live or work, or where the alleged infringement occurred.

18. External Websites

Our Site may contain links to websites operated by other organisations.

We are not responsible for the privacy practices, security or content of external websites. You should review the privacy information provided by those organisations before submitting personal data.

19. Changes to this Policy

We may update this Privacy and Cookie Policy from time to time to reflect:

  • changes in the law;
  • regulatory guidance;
  • changes to our services or business;
  • new service providers;
  • new tracking or analytics technologies; or
  • changes to how we use personal data.

The updated version will be posted on the Site and the date at the top will be revised.

Material changes may also be brought to your attention through the Site, by email or by another appropriate method.

20. Contact Us

For questions about this Policy, your personal data, a data-protection request or a complaint, contact:

ICT Business Advice LTD, trading as Luxbelle
Company number: 11152300
Email: luxbelle22@gmail.com