We recognize that you may be concerned about our use and disclosure of your personal information. Your privacy is very important to us, and the following will inform you of the information that we may collect from you, and how it is used. By using our Web site, you are accepting the practices described in this policy.
1. What information are you collecting? We collect personal information that can be used to identify you individually, such as your name, mailing address, phone number, email address, credit card number, and financial information. We also collect non-personal information, such as a domain name and IP Address. The domain name and IP address reveal nothing personal about you other than the IP address from which you have accessed our site. We also collect information about the type of Internet browser you are using, operating system, as well as which of our Web pages you have accessed.
2. How and when do you collect this information? We collect personal information from you when you provide it to us. For example, if you purchase a product sold through our online store, we may collect your name, mailing address, telephone number, credit card number, and email address. If you create an account, we may collect your name, mailing address, email address, and other information that we request in the registration process.
If you communicate with us regarding our Web site or our services, we will collect any information that you provide to us in any such communication.
3. How is my information used? We use personal information primarily for our own internal purposes, such as providing, maintaining, evaluating, and improving our services and Web site, fulfilling requests for information, producing and shipping the products that you order, and providing customer support.
We use non-personal information for internal purposes, such as maintaining, evaluating, and improving our services and Web site.
4. How is your Security? The security of your personal information is important to us. When you enter sensitive information such as a credit card number on our registration or order forms, we encrypt that information using secure socket layer technology (SSL).
We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
6. Will you disclose the information you collect to outside third parties? We will not sell or otherwise provide the information we collect to outside third parties for the purpose of direct or indirect mass email marketing.
We will disclose personal information and/or an IP address, when required by law or in the good-faith belief that such action is necessary to:
Cooperate with the investigations of purported unlawful activities and conform to the edicts of the law or comply with legal process served on our company
Protect and defend the rights or property of our Web site and related properties
Identify persons who may be violating the law, the rights of third parties, or otherwise misusing the our Web site or its related properties
8. What safeguards are in place? We are obligated to protect your personal information by making reasonable security arrangements against such risks as unauthorized access, use, collection, disclosure or disposal. Security measures have been integrated into the design, implementation and day-to-day operating practices as part of our commitment to protect the personal information it holds.
9. What else should I know about my privacy when online? Please keep in mind that whenever you voluntarily disclose personal information online – for example through e-mail, discussion boards, or elsewhere – that information can be collected and used by others. In short, if you post personal information online that is accessible to the public, you may receive unsolicited messages from other parties in return.
Ultimately, you are solely responsible for maintaining the secrecy of your personal information. Please be careful and responsible whenever you are online.
The EU General Data Protection Regulation (GDPR)
As of May 25, 2018, a new data privacy law known as the EU General Data Protection Regulation (or the “GDPR”) will be in effect through the EEA countries and Switzerland. The GDPR requires LiteLink Labs Inc. and those using our services to provide users with certain information about the processing of their “Personal Data. “Personal Data” is a term used in Europe that means, generally, data that identifies or can identify a particular unique user or device – for instance, names, addresses, cookie identifiers, mobile device, 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 EEA countries or Switzerland (so don’t rely on the below, if you’re not).
A. Legal grounds for processing your Personal Data
The GDPR requires us to tell you about the legal basis we’re relying on to process any Personal Data about you. The legal basis for us processing your Personal Data for the purposes set out 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. For this so-called “cookie consent” (which applies not only to “cookies” but also to mobile ad identifiers), we rely on our own compliance steps and our web and mobile partners’ compliance steps, designed to ensure that consent is collected and passed on to partners, and to ensure that we only facilitate the collection of legally obtained data. We do this 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 use 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 ad identifiers. A legitimate interest we rely on, for instance, is the tailoring of promotional communications to users of web and mobile properties, which is beneficial to users and is an integral part of the ecosystem by which freely available content is funded through advertising revenue. This also sometimes includes providing analysis of and reporting about ad campaigns, as well.
We also rely on legitimate interest when we use Personal Data to maintain 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.
B. Transfers of Personal Data
As LiteLink Labs Inc. 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 the EEA or Switzerland, and which have no data protection laws or laws that are less strict compared with those in Europe.
When we transfer Personal Data outside of the EEA or Switzerland, we take steps to make sure that appropriate safeguards are in place to protect your Personal Data. Feel free to 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.
C. 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. We generally render our own identifiers (e.g., those we use to “sync” our customers data to online users) inactive after 13 months, provided that we may retain them if we have a legal or significant operational need to do so, such as for auditing, corporate record-keeping, compliance accounting or security and bug-prevention purposes.
D. Your Rights as a Data Subject
The GDPR provides you with certain rights in respect of 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 (including profiling for online ad targeting).
Right To Access: If you wish to exercise your right to access Personal Data we process as a data controller, you may do so by requesting access through our contact us form. When we receive your request, we will provide you with current, step-by-step instructions to follow in order to obtain access. As we are required to verify a requestor’s identity prior to providing Personal Data, we will assess requests to exercise certain data access rights on a case-by-case basis: in doing so, we consider (a) the difficulty of verifying whether data that we hold and data we have linked to it truly and solely belongs to the data subject making the request, along with (b) the potential adverse affects on disclosure of personal data to the wrong individual. Because such improper disclosure would likely adversely affect the privacy rights and freedoms of the data subject, we may limit the Personal Data we make available.
Please note that we will only grant requests submitted via email for Personal Data for which we are a data controller, as explained further, below. Where we act as a processor for one of our customers, we will refer your request to that customer. Please identify the customer your request refers to (if possible), to simplify this process.
Right to Correct: If you wish to exercise your right to correct Personal Data, you may do so by contacting us at the contact information below.
We either collect these opt-out signals ourselves or receive them from the mobile apps we work with.
Right to Erasure. You also have the right to obtain the erasure of Personal Data concerning you that we hold as a controller. The above opt-out process satisfies this right. When a user opts-out through our partners (or through mobile device settings), and we receive this signal, we no longer use Personal Data to provide our advertising services. We will also manually delete your Personal Data if prefer that we do so; please contact us through our contact us form for further instructions if you wish to exercise this right manually. Please note, however, that we may retain copies of certain Personal Data on inactive or back-up files, for our own internal and necessary purposes, such as auditing, accounting and billing, legal or bug-detection. We will in most cases delete such data within 36 months, absent a compelling reason to retain it.
Right to Lodge Complaints. You have the right to lodge a complaint with a supervisory authority. However, we hope that you will first consult with us, so that we may work with you to resolve any complaint or concern you might have.
E. LiteLink Labs Inc. as a data controller and a data processor
EU data protection law makes a distinction between organisations that process Personal Data for their own purposes (known as “data controllers”) and organisations that process Personal Data on behalf of other organisations (known as “data processors”). As noted above, we are not always a data controller of the data in our possession, but are sometimes a data processor for other companies such as our customers. In such cases, we may direct your inquiry to the relevant data controller, since data controllers are the ones with primary responsibility for your Personal Data.
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