Privacy Policy

Lost Returns, Inc. Privacy Notice

v2.01 10.20.2021



  • 1. Introduction

We appreciate the trust you place in us when sharing your personal data. The security of that data is very important to us. In this document, we explain how we collect, use and protect your personal data.

We also explain what rights you have with regard to your personal data and how you can exercise those rights


  • 2. Who we are

Lost Returns, Inc. is a US based Corporation operating an Online Lost & Found Management Service that primarily assists Travel Industry Businesses located in the United States, Canada, the United Kingdom, Scotland, and Ireland with managing lost property logistics.

Our registered office address is:

Lost Returns, Inc.
127 West Fairbanks Ave. Suite 456
Winter Park, FL 32789

If you have questions about how we process personal data, or would like to exercise your data subject rights, please email us at [email protected] .


  • 3. Websites within scope

The following websites are within scope for this privacy notice:

We consider these predominantly US-based websites; see section 6 below for more information on our limited non-US data processing.

This notice also covers any additional personal data collected in the following online web applications:
It includes personal data that is collected through our websites, by telephone, through LiveChat and through any related social media applications.

  • 4. Collection of personal data

We collect personal data from you for one or more of the following purposes:

  • 1. To provide you with information that you have requested or that we think may be relevant to a subject in which you have demonstrated an interest.
  • 2. To initiate and complete commercial transactions with you, or the entity that you represent, for the purchase of products and/or services.
  • 3. To fulfil a contract that we have entered into with you or with the entity that you represent. In these circumstances it may be your entity, rather than yourself, that has provided us with your personal data.
  • 4. To provide access to trial software and to deliver a range of free material on request.
  • 5. To ensure the security and safe operation of our websites and underlying business infrastructure.
  • 6. To manage any communication between you and us.

The table in section 5 below provides more detail about the data that we collect for each of these purposes, the lawful basis for doing so, and the period for which we will retain each type of data.

Technical information

In addition, to ensure that each visitor to any of our websites can use and navigate the site effectively, we collect the following:

  • Technical information, including the IP (Internet Protocol) address used to connect your device to the Internet.
  • Your login information, browser type and version, time zone setting, browser plugin types and versions.
  • Operating system and platform.
  • Information about your visit, including the URL (Uniform Resource Locator) clickstream to, through and from our site.

From time to time we may use technologies, such as cookies and tracking pixels (also called 1x1 pixels or pixel tags), to collect the above information from your interaction with emails we send you. This enables us to focus our marketing to your needs, leading to more relevant emails to our subscribers. It also helps us to identify subscribers that are not engaged with our marketing emails, enabling us to remove them from our send lists.

What are cookies?

Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology.

For further information, visit

How do we use cookies?

Our Company uses cookies in a range of ways to improve your experience on our website, including:

  • Keeping you signed in
  • Understanding how you use our website

What types of cookies do we use?

There are a number of different types of cookies, however, our website uses:

  • Functionality - Our Company uses these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.
  • Advertising - Our Company uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. Our Company sometimes shares some limited aspects of this data with third parties for advertising purposes. We do not sell or lease our customer’s data.

How to manage cookies

You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result. In section 8 below, we identify your rights in respect of the personal data that we collect and describe how you can exercise those rights.

  • 5. Lawful basis for the processing of personal data

The table below describes the forms of personal data we collect and the lawful basis for processing this data. The organization of our business architecture, accounting and systems infrastructure and compliance means that all personal data is processed on common, group-wide platforms. We have processes in place to make sure that only those people in our organization who need to access your data can do so. A number of data elements are collected for multiple purposes, as the table below shows. Some data may be shared with third parties; where this happens, this is also identified below.

When we process on the lawful basis of legitimate interest, we apply the following tests to determine whether it is appropriate:

The purpose test – is there a legitimate interest behind the processing?

Necessity test – is the processing necessary for that purpose?

Balancing test – is the legitimate interest overridden, or not, by the individual’s interests, rights or freedoms?

Purpose of collection

Information category

Data collected

Purpose for collection

Lawful basis for processing

Data shared with?

Retention period

1. To provide you with information

Subject matter information

Name, company name, geographic location, email address, business sector.

To provide appropriate online or email information about products and services that you have requested.

Contractual fulfilment

Internally only.

Maximum eight years from the date the information is collected.

Six months if a marketing email is left unopened.

To provide further, related, online or email information and ongoing news updates in relation to the identified area of interest.

Legitimate interest

Internally only.

Telephone number.

Follow-up to ensure requested information meets needs and identify further requirements.

Legitimate interest

Internally only.

Personal contact information as provided through website forms or at trade shows or via any other means.

General mailing list subscription.


Internally only.

2. Transactional information

Transaction details

Name, physical address, email address, telephone number, bank account details (for credit accounts), other medium of content delivery.

To process purchase transactions for products and services with customers, and to ensure any transaction issues can be dealt with.

Contractual performance

Internally only.

Maximum eight years from the date of the performance of the contract.

Six months from the date the data subject has input personal information but has not proceeded with a transaction.

Eight years for VAT records from the performance of the contract.

For accounting and taxation purposes.

Statutory obligation

Internally and professional advisers.

Documentation should any contractual legal claim arise.

Legitimate interest

Internally and professional advisers.

Payment card data

PAN (primary account number), cardholder name, service code, expiration date

To fulfil purchase requests using payment cards.

Contractual performance

Payment card companies, all in line with the

Payment card company may retain for up to one year from date of transaction, for customer requested additional transactions.

3. Fulfilment information

Fulfilment data

Name, contact and identification details.

Appropriate shipping arrangements for delivery of goods

Contractual performance

Internally and any third-party logistics or supplier companies with which we contract in order to fulfil these requirements

Maximum six years from the date of the performance of the contract.

Name, contact and identification details.

Access to training courses, attendance registers.

Contractual performance

Internally and training venues.





Name, contact details.

Licensing details necessary for allocation and maintenance of a license purchased for use of software and related products, distance and e-learning.

Contractual performance

Internally and any third parties whose products or services you may have purchased from us.

Name, address(es), email address, contact details.

Actual delivery of products or services, in physical or digital form, that you may have purchased from us.

Contractual performance

Internally and any third-party logistics or supplier companies with which we contract in order to fulfil these requirements.

4. Security

Security information

Technical information, as described above, plus any other information that may be required for this purpose.

To protect our websites and infrastructure from cyber-attack or other threats and to report and deal with any illegal acts.

Legitimate interest

Internally, forensic, and other organizations with which we might contract for this purpose.

Relevant statutes of limitation.

5. Communications

Contact information

Names, contact details, identification details.

To communicate with you about any issue that you raise with us or which follows from an interaction between us.

Legitimate interest

Internally and, as necessary, with professional advisers.

Relevant statutes of limitation.

6. Product development

Survey data

Names, contact details, identification details.

To develop existing and new products that meet the expectations and requirement of our customers.


Internally and where additional consent is given for marketing purposes.

If anonymized for statistical research, this data may be kept indefinitely.

Where not anonymized, it shall be retained for a maximum of one year.


  • 6. Storage of personal data

Lost Returns, Inc. is a US-domiciled organization whose primary offices are in the US.

  • Most of our websites and web applications are hosted in the US and are administratively accessed only by our US-based staff. Customer facing software and applications where a User is provided a Login (username and password) are responsible for strict adherence to our Terms Of Service and any individual and/or entity is responsible for its use.
  • Our websites, as identified in section 3 above, are targeted at US, UK, Ireland and Scotland are accessed by staff located in the US. Our main website is hosted in the US. In instances where this is not the case, we have appropriate contractual and security measures in place to ensure that personal data is protected.
  • Our customer relationship management, marketing and accounting systems are either US-based or, in cases where this is not true, data transfers are made in accordance with the requirements of Regulation (EU) 2016/679 (the General Data Protection Regulation or “EU GDPR”) and may be based on the use of the European Commission’s Standard Contract Clauses for transfers of personal data outside the EEA.
  • We use a wide range of CSPs (Cloud service providers) as part of our processing environment. Unless we specifically state otherwise, we are, in respect of all these CSPs, the data controller.
  • Unless we specifically state otherwise, all the CSPs that we use utilize US processing facilities.
  • Our payment processors and banking arrangements are based in the US.
  • We ship and deliver physical products around the world; we therefore use logistics companies that are based outside the US and operate in other countries. We have appropriate legal and security relationships with those partners.
  • We resell products supplied by organizations outside the US. This may mean that our resale partners will have access to information about data subjects who purchase their products.
  • We operate a data retention policy in respect of all data, whether paper-based or digital, and those aspects of it that relate to personal data are contained in the table in section 5 above.


  • 7. Security measures

Our ISMS (information security management system) is secured using Secure Socket Layer 256 bit encryption and all our payment card processing is in compliance with the PCI DSS.

We have what we believe are appropriate security controls in place to protect personal data. Risk assessment, including assessing risks to the rights and freedoms of data subjects, is at the heart of our ISMS. We do not, however, have any control over what happens between your device and the boundary of our information infrastructure. You should be aware of the many information security risks that exist and take appropriate steps to safeguard your own information. We accept no liability in respect of breaches that occur beyond our sphere of control.


  • 8. Your rights as a data subject

As a data subject whose personal information we hold, you have certain rights. If you wish to exercise any of these rights, please email [email protected] or use the information supplied in the ‘Contact us’ section below. To process your request, we will ask you to provide two valid forms of identification for verification purposes. Your rights are as follows:

  • The right to be informed
    As a data controller, we are obliged to provide clear and transparent information about our data processing activities. This is provided by this privacy notice and any related communications we may send you.
  • The right of access
    You may request a copy of the personal data we hold about you free of charge. Once we have verified your identity and, if relevant, the authority of any third-party requestor, we will provide access to the personal data we hold about you as well as the following information:

    a) The purposes of the processing.
    b) The categories of personal data concerned.
    c) The recipients to whom the personal data has been disclosed.
    d) The retention period or envisioned retention period for that personal data.
    e) When personal data has been collected from a third party, the source of the personal data.

    If there are exceptional circumstances that mean we can refuse to provide the information, we will explain them. If requests are frivolous or vexatious, we reserve the right to refuse them. If answering requests is likely to require additional time or occasions unreasonable expense (which you may have to meet), we will inform you.
  • The right to rectification
    When you believe we hold inaccurate or incomplete personal information about you, you may exercise your right to correct or complete this data. This may be used with the right to restrict processing to make sure that incorrect/incomplete information is not processed until it is corrected.
  • The right to erasure (the ‘right to be forgotten’)
    Where no overriding legal basis or legitimate reason continues to exist for processing personal data, you may request that we delete the personal data. This includes personal data that may have been unlawfully processed. We will take all reasonable steps to ensure erasure.
  • The right to restrict processing
    You may ask us to stop processing your personal data. We will still hold the data but will not process it any further. This right is an alternative to the right to erasure. If one of the following conditions applies, you may exercise the right to restrict processing:
  1. a) The accuracy of the personal data is contested.
    b) Processing of the personal data is unlawful.
    c) We no longer need the personal data for processing, but the personal data is required for part of a legal process.
    d) The right to object has been exercised and processing is restricted pending a decision on the status of the processing.
  • The right to data portability
    You may request your set of personal data be transferred to another controller or processor, provided in a commonly used and machine-readable format. This right is only available if the original processing was on the basis of consent, the processing is by automated means and if the processing is based on the fulfilment of a contractual obligation.
  • The right to object
    You have the right to object to our processing of your data where:
    • Processing is based on legitimate interest;
    • Processing is for the purpose of direct marketing;
    • Processing is for the purposes of scientific or historic research; or
    • Processing involves automated decision-making and profiling.


  • 9. European Union representation

For those customers based within the EU, if you wish to exercise your rights under the EU GDPR, or have any queries in relation to your rights or general privacy matters, please email our representative at [email protected]. Please ensure you include the name of the website that you have engaged with in any correspondence you send to our representative.


  • 10. Contact us

Any comments, questions or suggestions about this privacy notice or our handling of your personal data should be emailed to [email protected]

Alternatively, you can contact us at our global HQ using the following address, telephone number or fax number:

GDPR Compliance Manager
Lost Returns, Inc.
127 West Fairbanks Ave. Suite 456
Winter Park, FL 32789
Office: 888-444-8980
Fax: 208-246-4732

Our call center is open 9:00 am – 5:30 pm ET, Monday to Friday. Our team may take a message and ensure the appropriate person responds as soon as possible.


  • 11. Complaints

Should you wish to discuss a complaint, please feel free to contact us using the details provided above. All complaints will be treated in a confidential manner.

Should you feel unsatisfied with our handling of your data, or about any complaint that you have made to us about our handling of your data, you are entitled to escalate your complaint to a supervisory authority. For the UK, this is the ICO (Information Commissioner’s Office), which is also our lead supervisory authority. Its contact information can be found at

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