LF Europe Limited is part of the Li & Fung group, and are the controllers for the personal data we have about you and the people who are responsible for keeping it safe and using it legally. LF Europe Limited knows that how we use your personal data is important to you so we are committed to only collecting the data that we need to provide to you and to keep it safe while giving you as much control as possible over how your data is used.
We process your data in accordance with relevant data protection and privacy laws because processing is necessary to fulfil our contract with you, because there is a legal obligation upon us or because it is in our legitimate interests. Where we need your consent to process data we will ask you clearly for that consent and provide a means for you to easily withdraw that consent at any time.
The sorts of information that we collect will include personal details including your name, address and date of birth, financial details and your buying history.
If you have any questions, comments or complaints about how we use your data, you can email our Data Protection Officer at firstname.lastname@example.org or write to our headquarters: LF Europe Limited, Centenary House, Centenary Way, Salford, Manchester, M50 1RF. You also have the right to complain to the UK regulator of privacy regulation, the Information Commissioner who is the independent regulator of your privacy rights. Their details can be found at www.ico.org.uk.
What do we use your data for?
We collect your personal data to fulfil the orders you make with us for products and services. When you place an order we will always need to collect name, address and payment details from you to fulfil our contract with you. We will only share this information with 3rd parties where it is absolutely essential (e.g. address details with our couriers, payment details with our payment service provider).
When it comes to payment details, this is all done in a secure process and we will never hold any of your payment details directly.
For email addresses and mobile telephone numbers, we will share these with our courier network so that they provide you with updates and notifications related to your delivery.
This includes showing you the products you want to buy, and knowing where you live and how to contact you. It also includes taking your payment details and processing them so you can pay for what you buy and checking you can afford to purchase what you have asked for and that you are of an appropriate age to do so.
Making sure the offers and suggestions we send you are appropriate for you by using your personal data to make predictions about what you will like helps make our marketing more efficient, keeping costs lower for all of our customers. We also try to encourage new customers to shop with us by sending them direct marketing, mainly through the post. We process details of how you browse our websites and use this information to target advertising when your browse the internet or through emails. We do this to ensure that our company grows and to link people with products that they are interested in.
As a major e-commerce and home shopping retailer we have an interest in a healthy industry of companies operating in a similar fashion. Sharing data helps us to grow this industry in ways that benefit our company and our customers. In order to grow our customer base we need to find the contact details of customers from other companies and this includes data brokers. Data is also valuable and as a private company we have to make a profit to survive and to continue to offer services to customers. So sometimes we will sell personal data directly to organisations who also wish to obtain new customers. This involves a financial transaction that helps our company to make reasonable profits and also to keep our product prices affordable for people who shop with us.
We process data about you to make an initial offer of credit based on verifying your identity, eligibility and financial standing. We collect information from you directly to do this and we also enhance this data with information from other sources. We also have to process data to let our regulators know how we are treating you and also how well your management of your account reflects on your approach to credit generally. We have to ensure that we do not get defrauded and that we can recover money we are owed so we have to process information about the devices you use to interact with us including digital fingerprinting to prevent fraud. We also have to process information about your circumstances to ensure we take a responsible approach if you get into financial difficulties or to help us to enforce our legal rights if you decline to pay. Specifically we process data about your payment history with us and we share it with credit reference agencies. We do not use your consent to do this as this would incorrectly suggest that there is a choice for you when if fact we are required to share such data with the agencies as part of our duties as a responsible provider of credit.
Employer / Recruitment
We process data for the purposes of managing our employees and fulfilling our legal obligations to them. We also process data for the purposes of recruiting new employees.
Should you apply for a position within LF Europe Limited we will keep your details for up to a period of six months so that we may inform you of suitable roles within our business. Should you wish to only be considered for a single role, then please make us aware within your application.
Should you work within LF Europe Limited, we will keep your personal details on file for the duration of your employment, and should you/us terminate that employment then we will retain it for as long as is necessary to fulfill our legitimate interests and in accordance with our data retention periods in some cases up to a maximum of 30 years appropriately secured
International transfers of data
In the course of providing our services, we may transfer your personal information outside the European Economic Area. Where this is the case, we will employ appropriate security measures to protect your personal information to at least the same standard as found in the EU. These will include the EU/US Privacy Shield and standard contract clauses provided by the EU Commission.
General business activities
Should you have any communication with employees within our company on the grounds of conducting general business affairs, then your email address and telephone number may be used for the purposes of individual business communications.
Cookies are small files that are downloaded to your computer to help you use our website and improve your online experience with LF Europe. No personal data is collected from cookies or stored on your computer. They are a simple file of numbers and letters which then relate back to the information a website securely stores about you. They are used to remember what you have in your basket, to remember who you are when you log in and also to track the overall way visitors use our website so that can constantly improve their user experience.
We also use some 3rd party cookies that are used to show you more relevant products and adverts on other websites on the internet - including social networks such as Facebook and Instagram.
Types Of Cookie
Session cookies - only last for the duration of your browsing session on the website.
Your web browser would normally delete when the session expires.
Persistent cookies - these last longer than the browser session e.g. if you log into a website and then return to the website some days later, the website remembers who you are and displays a welcome message to you. Persistent cookies enable this to happen.
First party cookies - these are set by the domain (or sub-domain) in the web browser.
Third party cookies - these are set by a different domain to the one on the website you are looking at. Third party cookies are used for a variety of reasons. They could be used if you visited one of the pages on our website that contained embedded links or content. One other popular use is to show you more relevant products and adverts on other partner websites on the internet - including social networks such as Facebook and Instagram.
Cookies are usually automatically set as default within your browser, due to the number of websites in which they are mandatory, however you can edit this or delete cookies through the settings within your internet browser.
Links to Other Sites
We may at time provide links to other websites. Where we do this, the links we provide are in good nature, however these linked sites are independent and therefore adhere to separate policies. Hence LF Europe has no responsibility or liability for content delivered on these websites and platforms.
What happens if things change?
If we make moderate changes we may highlight them on the front page of our website or in some other manner.
Li & Fung Limited specialises in the management of global supply chain for brands and retailers around the world. The customers of the group include department stores, hypermarkets, specialty stores and chain shops located globally.
The purpose of this document is to provide an overview of the approach to tax of the Li & Fung Group.
This tax strategy document is published in accordance with Schedule 19 of the UK Finance Act 2016 by Li & Fung Limited in respect of all the UK entities within the Group (“Li & Fung” or “UK Group”). This document has been approved by the directors of the UK Group and will be reviewed and where necessary, updated, on a periodic basis.
Approach to Tax and Tax Governance
Li & Fung’s approach to tax is based on compliance with our reporting requirements and adherence with the relevant tax laws and regulations to pay the correct amount of tax, making use of government offered reliefs where applicable, with a view to deliver value to our shareholders.
The following covers Li & Fung’s (A) Governance towards compliance and reporting (B) Attitude/approach towards tax planning and risk management and (C) Approach towards working with HMRC.
Governance towards Compliance & Reporting
In accordance with Li & Fung’s Code of Conduct and Business Ethics, employees are required to ensure all transactions are properly included in the books and records. All accounting information must be reliable so that it can be used for preparation of financial statements, statutory audit and other compliance purposes.
As a major subdivision of a Hong Kong listed company, the UK Group are well aware of the importance of compliance with the relevant tax laws, obligations and tax practices regarding the tax filing and payment of taxes.
The UK Group engages with professional tax advisors to ensure tax compliance. In addition to our own research and training, we expect our professional advisors to ensure the UK Group are kept fully informed of the latest development of tax regulations and to ensure all transactions, as well as tax returns, are compliant with the relevant laws and regulations.
The Senior Accounting Officer (“SAO”) and local finance team in the UK, which is made up of appropriately qualified individuals, are responsible for the tax compliance matters of the “UK Group”, and have implemented controls and processes to manage this process. The tax matters of the “UK Group” are closely monitored and scrutinised by the Corporate tax team in Hong Kong, which comprises of experienced tax professionals. Major tax issues are also discussed and addressed during Audit Committee meetings.
The Group’s Attitude/Approach towards Tax Planning and Risk Management
Li & Fung does not implement aggressive tax planning where the sole or dominant purpose is to obtain a tax benefit. Business structures and transactions are planned and designed to reflect the commercial requirements and cater to the operational needs of the group, although tax efficiency may also be taken into account as part of the planning/design process.
As the group has strict governance on compliance and reporting, the “UK Group” is not permitted to take material tax risks or expose the Global Group to uncertain tax positions. As such, whenever the group deals with any significant transactions or when they experience uncertain tax positions, the “UK Group” seeks advice from professional tax advisors and obtains consent from the Corporate office in Hong Kong.
The Group’s Approach towards Working with HMRC
The “UK Group” seeks to maintain an open and honest relationship with HMRC, in particular with our allocated Customer Relationship Manager (“CRM”). The SAO and local finance personnel regularly meet with the CRM to update HMRC on the latest business developments and key transactions of the “UK Group”.
Where there is uncertainty in the interpretation of tax regulations and other questions relating to current tax practices, we take advice from professional advisors, and where appropriate, seek advice from HMRC to gain certainty on the approach taken.
Date Published – 22 December 2017