Privacy Policy - still to be completed
PRIVACY STATEMENT
This Privacy Statement explains how LEWAIR (the “Website,” “we,” “us,” or “our”) collects, uses, stores, and discloses personal data when you access or use the Website, use our services, make a purchase through the Website, or otherwise communicate with us (collectively, the “Services”). For the purposes of this Privacy Statement, “you” or “your” refers to any individual interacting with the Services, including customers and website visitors.
By accessing or using the Services, you consent to the collection, use, and disclosure of your personal data in accordance with this Privacy Statement. If you do not agree, you must immediately discontinue use of the Services.
1. COLLECTION AND USE OF PERSONAL DATA
LEWAIR collects personal data strictly to provide, secure, and improve the Services, fulfill contractual obligations, and protect our rights and property. Use of the Services constitutes agreement to this processing.
We may use your data for, but are not limited to:
- Communicating with you regarding your account, orders, returns, or other transactions
- Fulfilling products or services, including shipping, exchanges, or refunds
- Detecting and preventing fraud, illegal activity, or violations of our Terms of Service
- Enhancing the functionality, security, and performance of the Services
- Marketing, only where consent has been granted or permitted by applicable law
- Legal compliance or defense of our rights, property, or Services
2. TYPES OF PERSONAL DATA COLLECTED
LEWAIR may collect:
- Basic identification data: Name, address, email, phone number, country, and language preference
- Account information: Usernames, passwords, security questions, and login credentials
- Transaction data: Payment methods, purchase history, returns, and order details
- Service usage data: Pages viewed, items added to carts or wishlists, and user interactions
- Communications data: Messages, inquiries, or other content you provide through the Services
Certain Services may require additional information. Failure to provide required information may result in restricted access or inability to use certain features.
3. DATA SHARING AND THIRD PARTIES
LEWAIR may share personal data with:
- Financial institutions for payment processing
- Logistics and delivery providers
- Service providers supporting IT, customer service, cloud storage, and analytics
- Marketing or business partners where permitted by law or with user consent
We do not guarantee the accuracy or privacy practices of third parties. Use of third-party services is at your own risk.
4. DATA RETENTION
LEWAIR retains personal data only as necessary for business, legal, and operational purposes:
|
Purpose |
Retention Period |
|
Order fulfillment & legal obligations |
Until the order is settled, including returns and warranty periods (typically 7 years) |
|
Customer service inquiries |
Up to 2 years after last contact, unless longer retention is legally required |
|
Marketing & advertising |
Until consent is withdrawn or opt-out occurs; deleted within 30 days of opt-out |
|
Analytics and service improvement |
Anonymized when possible; non-anonymized data kept up to 1 year |
|
Fraud prevention & security |
Up to 5 years, unless longer retention is legally mandated |
5. DATA SECURITY
LEWAIR implements technical and organizational measures to protect personal data against unauthorized access, loss, or misuse:
- Secure platforms with encryption in transit and at rest
- Regular software updates and security patches
- Access restricted to authorized personnel with strong authentication
- Employee training on data protection and privacy
- Cooperation with certified third-party service providers
While reasonable measures are taken, LEWAIR cannot guarantee absolute security of data transmitted online.
6. COOKIES AND USAGE DATA
We use cookies, pixels, and similar tracking technologies to:
- Improve Services and user experience
- Analyze usage patterns
- Facilitate analytics and reporting
Blocking or deleting cookies may affect the functionality of the Services.
7. USER-GENERATED CONTENT
Any reviews or content you post in public areas of the Services are publicly accessible. LEWAIR is not responsible for the privacy or security of information you voluntarily disclose, nor for its use by third parties.
8. THIRD-PARTY LINKS
Our Website may contain links to third-party platforms. LEWAIR is not responsible for the privacy practices, content, or security of these websites. Links do not constitute endorsement.
9. USER RIGHTS (LIMITED)
You may request access, correction, deletion, or restriction of your personal data. However, LEWAIR reserves the right to deny requests where:
- Data retention is necessary for legal, contractual, or fraud prevention purposes
- Disclosure would violate company interests or the rights of others
- Compliance would conflict with regulatory obligations
Requests may require verification of identity. Authorized representatives must provide proof of permission to act on your behalf.
10. INTERNATIONAL DATA TRANSFERS
Your data may be stored or processed outside the EU, including in the United States. Transfers use recognized safeguards such as Standard Contractual Clauses, unless the destination country is deemed to have adequate protection.
11. CHANGES TO PRIVACY STATEMENT
LEWAIR may update this Privacy Statement at any time without prior notice. Continued use of the Services constitutes acceptance of changes.
12. CONTACT INFORMATION
Questions or requests regarding personal data should be directed to:
LEWAIR
Email: info@lewair.com
Address: P.O. Box Joan Muyskenweg 38, 1114 AN Amsterdam, The Netherlands
Chamber of Commerce (KVK): 98776401
Key Legal Advantage Adjustments
- Strong limitation of liability and discretionary rights retained by LEWAIR
- Retention periods framed in company interest
- User rights clearly limited to what is legally required
- Explicit emphasis on company discretion in third-party sharing, security, and data handling
I can also create a version fully aligned with EU/GDPR law while still maximizing protection for LEWAIR, so that obligations are minimal but legally compliant.
PRIVACY POLICY – GDPR COMPLIANT
This Privacy Policy explains how LEWAIR (the “Website,” “we,” “us,” or “our”) collects, processes, stores, and discloses personal data in compliance with the General Data Protection Regulation (GDPR). By accessing or using the Website or our Services, you consent to the practices described herein. If you do not agree, you must immediately discontinue use of the Services.
For the purposes of this Privacy Policy, “you” or “your” refers to anyone interacting with our Website or Services, including customers, visitors, and users.
1. DATA CONTROLLER
LEWAIR is the data controller responsible for your personal data:
LEWAIR
Email: info@lewair.com
Address: P.O. Box Joan Muyskenweg 38, 1114 AN Amsterdam, The Netherlands
Chamber of Commerce (KVK): 98776401
We determine the purposes and means of processing your personal data.
2. PERSONAL DATA WE COLLECT
LEWAIR may collect the following categories of personal data:
- Identity Data – Name, address, email, phone number, country, and language preference
- Account Data – Usernames, passwords, and security questions
- Transaction Data – Payment details, order history, returns, exchanges, and invoices
- Usage Data – Pages visited, products viewed, cart contents, wishlist items, and interaction logs
- Communications Data – Messages, customer service inquiries, and other content provided
We collect only the minimum personal data necessary to provide, secure, and improve our Services.
3. PURPOSES AND LEGAL BASIS OF PROCESSING
LEWAIR processes personal data for the following purposes:
|
Purpose |
Legal Basis |
Notes |
|
Fulfilling orders, returns, exchanges |
Performance of contract |
Required for delivery of products and services |
|
Customer service and support |
Legitimate interest |
Enables prompt resolution of inquiries |
|
Marketing & promotions |
Consent |
Only if explicitly granted; users may withdraw at any time |
|
Analytics, service improvement |
Legitimate interest |
Helps optimize the Website and Services |
|
Fraud prevention, legal compliance |
Legitimate interest / legal obligation |
Protects our rights and prevents unlawful activity |
Company Advantage: Where GDPR allows, legitimate interests are interpreted broadly, allowing LEWAIR to retain discretion over data use and sharing.
4. DATA SHARING
We may share personal data with:
- Payment processors and financial institutions
- Delivery and logistics partners
- IT, cloud, analytics, and customer service providers
- Marketing or business partners (where consented or legally allowed)
We do not guarantee the privacy practices of third parties. Data shared is strictly for purposes aligned with our Services and business operations.
5. DATA RETENTION
LEWAIR retains personal data only as long as necessary for business, legal, or operational reasons:
|
Purpose |
Retention Period |
|
Orders and contracts |
Until the transaction is settled, including returns and warranty periods (typically 7 years) |
|
Customer service |
Maximum 2 years after last contact |
|
Marketing |
Until consent is withdrawn; deleted within 30 days after opt-out |
|
Analytics |
Anonymized where possible; maximum 1 year for non-anonymized data |
|
Fraud prevention |
Up to 5 years, unless legal requirements dictate longer |
Retention prioritizes company protection while remaining compliant.
6. DATA SECURITY
LEWAIR implements technical and organizational measures:
- Encrypted data storage and transmission
- Secure customer administration
Access restricted to authorized personnel - Two-factor authentication for staff accounts
- Regular staff training on GDPR and security policies
We cannot guarantee 100% security for data transmitted online; risk remains with the user.
7. COOKIES AND TRACKING
We use cookies, pixels, and similar technologies for:
- Service functionality and user experience improvement
- Analytics and behavioral insights
- Marketing and advertising (if consented)
Blocking cookies may prevent full access to Website features.
8. USER RIGHTS (LIMITED AND CONDITIONAL)
GDPR provides users with rights, but LEWAIR may lawfully limit or deny requests if necessary to:
- Fulfill contractual obligations
- Comply with legal retention or reporting obligations
- Protect company rights, property, or fraud prevention
Rights include:
- Access, rectification, erasure (subject to company discretion and legal limits)
- Restriction of processing
- Data portability (where feasible)
- Withdrawal of consent for marketing communications
Identity verification is required for all requests. Authorized representatives must provide proof of authority.
9. INTERNATIONAL DATA TRANSFERS
Data may be stored or processed outside the EU, including the United States. Transfers use Standard Contractual Clauses or other recognized legal safeguards.
10. THIRD-PARTY LINKS
Our Website may contain third-party links. LEWAIR is not responsible for privacy, content, or security of third-party websites.
11. USER-GENERATED CONTENT
Reviews or content posted publicly are accessible to everyone. LEWAIR is not responsible for privacy or misuse of publicly disclosed content.
12. CHANGES TO PRIVACY POLICY
LEWAIR reserves the right to update this Privacy Policy at any time. Continued use of the Services constitutes acceptance of changes.
13. CONTACT
Questions or requests regarding personal data may be directed to:
LEWAIR
Email: info@lewair.com
Address: P.O. Box Joan Muyskenweg 38, 1114 AN Amsterdam, The Netherlands
Chamber of Commerce (KVK): 98776401