1 TYPES OF INFORMATION WE COLLECT
We may collect different categories of information from you, either personal or non-personal information, as defined below and depending on the nature of your interaction with the Website, all as detailed below.
Non-personal information is information that may be made available or gathered through your use of the Website and may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information such as device brand, screen size, type of operating system, type of device, language preference, the time and date you access our Website, your actions within our Website (e.g., registration, pages viewed, etc.), the URLs from which you were directed to our Website, search queries within our Website, etc., and approximate geo-location (country). To clarify, based on this type of information we are not aware of your identity.
Personal information is individually identifiable information, namely, information that identifies an individual or mat with reasonable effort identifies an individual. Personal information includes information voluntarily provided by you as well as certain identifiers, such as internet protocol (hereinafter referred to as »IP«) address.
You are not required by law to provide us with certain personal information. You can always refuse to provide certain personal information, however, you acknowledge that such refusal may prevent you from engaging in certain activities within the Website.
In the event we combine personal information with non-personal information, the combined information will be treated as personal information for as long as it remains combined.
2 HOW WE USE YOUR INFORMATION
We use the information we collect from you for delivering the Websites and to operate our business. We use it also for improving our Websites, for enhancing security and for analytics and research purposes to make sure we provide you with the best experience. In addition, we use your information to promote our Websites and for complying with our legal obligations.
We use your technical, website usage and classical information for the following purposes:
- Delivering our Websites: developing, delivering, tailoring and improving our content, analyzing trends in connection with usage of the Websites, administering the Websites, and customer communications.
- Promoting our Websites: when you use our Websites we may promote our Websites.
- Analytics and research: understanding and analyzing trends in connection with the usage of Website, auditing, learning about user behavior on the Websites (how often you use the Website, the events that occur on the Website, aggregated usage, performance data, etc.).
- Security: We use your information for enhancing the safety and security of our Websites.
- Our legal obligations: We use your information when we are required to do so by law.
4 HOW WE SHARE YOUR INFORMATION
We cannot provide all services necessary for the successful operation of the Website by ourselves. We must, therefore, share collected information with third parties, including analytics providers, and other third-party service providers that support the Website, including Third Party Social Networks (collectively referred to as “Partners”). We may share information that can be used to personally identify your device (e.g. IP address) for the purposes of delivering our Websites and conducting analysis and research. We also reserve the right to disclose your information (including personally identifiable information) when we are legally required to do so, to disclose your information in an anonymous and aggregated manner, meaning you could not be personally identified from it.
5 THIRD-PARTY SOCIAL NETWORKS
6 THIRD-PARTY SITES AND SERVICES
You can voluntarily subscribe to our newsletter with your email address, which provides you with the latest news, updates or promotions about our services and/or products. The legal basis for processing is your consent. Your email address will be kept as long as you stay subscribed to our newsletter.
You can unsubscribe at any time by using the unsubscribe button within the body of each email message or by contacting us at firstname.lastname@example.org.
8 HOW OUR PARTNERS MAY USE YOUR INFORMATION
We strive to commit our partners to use the information solely for the purposes as stated above. If they use information that might be considered as personal information, they should use it solely for the purposes of providing the service to us, but for any other purposes, they should use the information solely on an anonymized and aggregated basis. Notwithstanding the above, we cannot guarantee that our partners will adhere to the contractual obligations or acceptable business practices.
In addition, partners may use their own tracking technologies (including and without limitation: cookies, web beacons, HTTP cache, and local shared objects) to compile anonymous information about visitors to the Websites. Partners may share anonymous information that they collect with their clients. We strive to ensure that this information is only disclosed to such third parties in an anonymized and aggregated manner.
9 PROTECTION OF PERSONAL INFORMATION
10 DATA RETENTION
We retain this collected information as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws, or until individuals express a preference to opt-out or delete their personal information. We may, at our sole discretion, delete or amend information from our systems, without notice, once we deem it is no longer needed for such purposes.
11 THE EU GENERAL DATA PROTECTION REGULATION (EEA RESIDENTS)
As of May 25, 2018, a new data privacy law known as the EU General Data Protection Regulation (the “GDPR”) will be in effect through the EEA, Switzerland, and the UK. The GDPR requires Login5 and those using our Websites to provide users with certain information about the processing of their “Personal Data.” “Personal Data” is a term used under the GDPR that means, generally, data that identifies or can identify a particular unique user or device – for instance, names, addresses, cookie identifiers, Mobile IDs, precise location data, and biometric data.
To comply with the GDPR, we provide the below representations and information, which are specific to persons located in the EEA, Switzerland, or the UK and to the processing of personal data in the context of the activities of Login5.
- Legal Grounds for Processing Personal Data
The GDPR requires us to tell you about the legal ground we are relying on to process any Personal Data about you. The legal grounds for us processing your Personal Data for the purposes set out in Section 2 above will typically be because:
- You provided your consent. In order to store and gain access to information stored on your device, we rely on your consent. We do so to fulfill our obligations under the ePrivacy Directive. We may choose to obtain consent in other cases as well, in which case we will adhere to applicable laws relating to such consent and its withdrawal;
- The processing is in our legitimate interest. In some cases, we rely on legitimate interest as a legal basis for processing Personal Data, in order to provide our and/or other data controllers’ services. Such processing goes beyond the original collection of mobile IDs. A legitimate interest we rely on, for instance, is maintaining the security of our services, such as to detect fraud or to ensure that bugs are detected and fixed;
- Contractual relationships. Sometimes, we process certain data as necessary under a contractual relationship we have (such as our customer records and contact information);
- Legal obligations. Finally, some processing of data may be necessary for us to comply with our legal or regulatory obligations.
- Transfers of Personal Data
As Login5 works with global companies and technologies, we may need to transfer your Personal Data outside of the country from which it was originally provided. For instance, we may transfer your data to third parties that we work with who may be located in jurisdictions outside of the EEA, Switzerland, or the UK, and which have no data protection laws or laws that are less strict in comparison to those in Europe.
When we transfer Personal Data outside of the EEA, Switzerland, or the UK, we take steps to ensure appropriate safeguards are in place to protect your Personal Data. Please contact us at the contact information below for more information about the safeguards we have put in place to protect your Personal Data and privacy rights in these circumstances.
- Personal Data Retention
As a general matter, we retain your Personal Data for as long as necessary to provide our services, or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements.
- Your Rights as a Data Subject
The GDPR provides you with certain rights with respect to Personal Data that data controllers hold about you, including certain rights to access Personal Data, to request correction of the Personal Data, to request to restrict or delete Personal Data, and to object to our processing of your Personal Data.
- Right to object. You have the right to object to the processing of your personal information that is processed on the grounds of legitimate interests. You are always free to opt-out from the future collection of your personal information by us and our partners by not accessing and/or using the Websites.
- Right of access. You have a right to know what information we hold about you and in some cases to have the information communicated to you. If you wish to exercise this right please contact us by letting us know that you wish to exercise your right to access and what information, in particular, you would like to receive. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information. Please note that we may not be able to provide all the information you ask for, for instance, if the information includes personal information about another person. Where we are not able to provide you with the information that you have asked for, we will explain to you why. We will try to respond to any request for a right of access as soon as possible, but we will always do so within 1 month of receipt of your request and verification of your identity.
- Right to correct personal information. We try to keep the information that we hold about you accurate and up to date. Should you realize that any of the information that we hold about you is incorrect, please contact us via email@example.com and we will correct it as soon as we can.
- Data deletion. You have a right to request deletion of the personal information that we hold about you. Should you wish to do that, please contact us at firstname.lastname@example.org. We reserve the right to ask to provide us additional information to verify your identity before we can start processing your request. Once we receive all information we need in order to be able to identify you, we will delete your personal information you requested us to delete as soon as possible, but we will always do so within 1 month of receipt of your request and verification of your identity. Please note that we may still retain some or all of that information, for example for complying with our legal obligations and protecting or enforcing legal rights. We may also retain your information in an anonymized form.
- Data portability. In some circumstances, you have the right to request that we provide you with the personal information which you have provided to us, so you can transfer this information to another data controller. Should you wish to do that, please contact us at email@example.com.
- Restriction of processing. In some cases, you may have the right to request a restriction of the processing of your personal information.
Right to file a complaint. You have the right to file a complaint against us. To do so, contact the supervisory authority in your country of residence.
12 QUESTIONS OR COMPLAINTS
You can direct any questions or complaints about the use or disclosure of your personal information to us at firstname.lastname@example.org. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of personal information within 45 days of receiving your complaint.
14 CONTACT US
LOGIN5 FOUNDATION, LAST UPDATE JANUARY 2021