Privacy policy
[Last Revised: March 21, 2023]
(1) INTRODUCTION
Livger Ltd (“Company” or “us” or “our”) respect the privacy of the users of its website and Services (“user” or “you” or “your”, and “Website” respectively). This Privacy Policy (“Policy”) details the Company’s privacy practices related to the collection and processing users’ data who access our Website and interact with our Services, as required, among others, according to the EU General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”).
This Policy is an integral part of our Terms of Use. Definitions herein shall have the same meaning as defined therein.
In the event the CCPA applies to you as a California resident – please review section 4 below.
We encourage you to review this Policy before you use the Services or browse the Website.
(2) POLICY UPDATES
We may, at our discretion, update or amend this Policy, at any time and every 12 months, in the event required under applicable law. Any amendments shall be effective upon publication of the revised Policy. The last revision will be reflected in the “Last Revised” heading. In the event of what we believe as material amendments we will make best efforts to provide applicable notification. Please review this Policy periodically.
(3) TYPES OF DATA COLLECTED THROUGH THIS WEBSITE AND OUR USE AND LAWFUL BASIS OF SUCH DATA UNDER THE GDPR
Whenever a user accesses this Website and use the Services available therein, we may collect the following types of data:
- Non-Personal Data – meaning, non-identifiable aggregated data, mainly technical data transmitted by the user’s device and aggregated use of the Services. This data is not used to identify individual users.
- Personal Data – meaning, individually identifiable information.
In general our lawful basis for processing Personal Data under the GDPR is as follows (i) we process user’s Personal Data in the event we have a legitimate interest to do so (e.g., IP for fraud detection and calculating payments); (ii) we process user’s Personal Data in order to perform a contract, in the event a user have contacted us and requested for a specific service; or (iii) we process user’s Personal Data in the event we have obtained the user’s consent for such processing, where required under applicable law.
The table below was designed in an easy to read format, in order for you to easily understand how we use the data collected through this Website:
|
Data |
Our Use |
|
Contact Details. when a user contacts us by any means of communications (i.e., through the Website’s online form or by sending us an email) it will be requested to provide us its contact details such as name, email address, or phone number. |
These contact details will be used by us solely in order to respond to the user’s request and provided the needed information or support. In some cases, when we believe it is needed, we will save the applicable contact history. |
|
IP, Unique Click ID and Technical Non-Personal Data. The technical Non-Personal Data we collect includes, among others, software and hardware information, type of operating system, type of device, type of browser, language preference, the time and date you access and use the Services, internet service provider, navigation in the Website and duration of your visit, statistical browsing information, approximate geographical location (extracted through IP), directing URLs, etc. We or our third party partners offering the Third Party Services may generate a unique click ID when you access their Third Party Service through our Website. |
This data will be used by us to fulfil our legitimate interests of: tracking usage statistics and traffic flow related to our Website; improve and customize our Website and Services as well as remarketing (as detailed below); operate, maintain, protect and manage our Website and Services. We may also use IP addresses and unique IDs for the purpose of calculating the fees we are entitled to receive from our business partners. |
Note that, we do not combine Personal Data voluntarily provided by you with the Non-Personal Data. However, if we do so, we will treat the combined information as Personal Data.
(4) PRIVACY NOTICE FOR CALIFORNIA RESIDENTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT
This section is intended for California Residents under the California Consumer Privacy Act of 2018 (“CCPA”), applies solely to all visitors, users, and others who reside in the State of California (“Consumer” or “you”), as defined under the CCPA. Any terms defined in the CCPA have the same meaning when used in this section.
(5) TYPES OF PERSONAL INFORMATION WE COLLECT
Under the CCPA, “Personal Information” is defined as any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device. The categories of Personal Information that we collect (and have collected within the last 12 months) are detailed in the table below.
Please note that under the CCPA Personal Information does not include: publicly available information from government records and de-identified or aggregated consumer information, information excluded from the CCPA’s scope (e.g., health or medical information covered by applicable laws such as the Health Insurance Portability and Accountability Act of 1996 (HIPAA)); and information covered by certain sector-specific privacy laws (e.g., the California Financial Information Privacy Act (FIPA)).
|
Category |
Examples |
Collected |
|
A. Identifiers. |
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. |
Yes |
|
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). |
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. |
Yes |
|
C. Protected classification characteristics under California or federal law. |
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). |
No |
|
D. Commercial information. |
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
No |
|
E. Biometric information. |
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. |
No |
|
F. Internet or other similar network activity. |
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. |
Yes |
|
G. Geolocation data. |
Physical location or movements. |
No |
|
H. Sensory data. |
Audio, electronic, visual, thermal, olfactory, or similar information. |
No |
|
I. Professional or employment-related information. |
Current or past job history or performance evaluations. |
No |
|
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). |
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. |
No |
|
K. Inferences drawn from other personal information. |
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
No |
SHARING DATA
We may disclose your Personal Information to a third party for a business purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.
We share your Personal Information with the following categories of third parties:
- Service providers
- Data aggregators
- Business Partners
DISCLOSURES OF PERSONAL INFORMATION FOR A BUSINESS PURPOSE
In the preceding twelve (12) months, the Company has disclosed the following categories of Personal Information for a business purpose:
Category A: Identifiers.
Category F: Internet or other similar network activity.
(5) HOW DO WE COLLECT DATA?
The Non-Personal Data and Personal Data is collected either when a user voluntarily provide us with the data or through the use of cookies and similar technologies (as elaborated in the Section below).
(6) COOKIES
We gather some information automatically through the use of third parties’ cookies and similar tracking technologies (“Cookies”), placed within the Website. “Cookies” are small text files that are placed on your device or browser by a web server when you access our Website.
Our use of Cookies is made for the purpose of making the interaction between our user’s and the Services more efficient, by, for example, enabling automatic activation of certain features, and remembering user’s preferences etc. In addition, we use Cookies in order to serve tailor ads, known as “remarketing”.
We may permit third parties to use cookies or other tracking technologies to collect information about your online and application usage activities across our Services, and for the purposes detailed above, as follows:
|
Cookie |
Purpose |
Privacy Policy and Opt-Out |
|
Google AdWords |
Used for advertising & remarketing. Our use of these services is intended to serve relevant ads tailored to you based on the webpages you have viewed by placing a cookie on your device (i.e., will show you ads relating to that webpage). |
|
|
Google Analytics |
Used in order to track and analyse the use of our Website, and for statistical internal purposes, such as, to know how many users have accessed our Website. |
For additional information on our use of Google products, click here.
Note that – our third party business partners offering the Third Party Services may use cookies as well.
Note that, you may be able to disable some Cookies through your device or browser settings. In the event you disable cookies, some features of our Services may not operate properly. More information about your ability to disable cookies, can be found here (as applicable to your browser): Google Chrome; Firefox; Internet Explorer; Safari; Edge; Opera
(7) DISCLOSURE OF DATA
We will share Personal Data collected solely in the following events:
- we may share your information in order to comply with any applicable law, legal process, or governmental request as well as for the purpose of enforcing our agreements and policies, establish, exercise or defend our rights and third party’s rights, and any applicable needed action in this regard. In addition, we may share your information to prevent or detect illegal activities, wrongdoing, and suspected fraud.
- We may disclose Personal Data to our service providers so that they can perform the requested services on our behalf. We prohibit such Service Providers from using your Personal Data for any purposes.
- We may share your information with third parties when you provide your consent to a particular disclosure. However, if we do share your information based on your consent, following such disclosure, the information shared will be subject to such third party’s privacy practices which might differ from our practices detailed herein.
- We may share your information with a parent company, subsidiaries, joint ventures, or other companies under a common control (“Affiliated Companies“) solely if and when applicable or necessary. In addition, we may share information, in the event of a corporate transaction (e.g. sale, merger, consolidation, etc.), provided, however, that our Affiliated Companies or acquiring company will be subject to the obligations detailed herein with respect to your Personal Data;
- We may share IPs collected by us (as detailed above), for the purpose of operating and improving our business, providing the Services and remarketing, as well as to detect fraud, security or technical issues in connection with the Site.
- We may disclose your personal information to a third party for a business purpose (under the CCPA). When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We may share the Non-Personal Data as well as use, disclose or transfer aggregated and processed data to third parties for any purpose we find applicable to our business operation.
(8) DATA RETENTION
We retain the data we collect solely for as long as required to fulfill the purposes for which it was initially collected until a deletion request is met and complied with the terms as set forth in this Policy, or in the event, we are required to do so in order to comply with legal, tax and accounting requirements. In addition, we will retain the information we believe is needed in order to protect our rights and interests, in accordance with applicable laws.
(9) DATA SECURITY
We employ security measures to protect your data from unauthorized access, use, disclosure, or accidental loss and destruction. Note that, 100% security can never be provided, thus we will not be responsible for unauthorized acts that are beyond our control. In the event of a data, incident relates to your Personal Data, we will make reasonable efforts to provide notification (in the event required under applicable laws).
If you feel that your privacy was treated, or if suffered from an individual attempt to abuse our Website or Service or acted in an inappropriate manner, please contact us directly at [email protected].
(10) THIRD-PARTY CONTENT AND SITES
This Website includes links to websites and services not owned or operated by us and which their privacy practices may differ from ours. We are not and will not be held responsible for such third parties’ privacy practices once you leave our Website.
(11) USER’S RIGHTS AND OPT-OUT CONTROLS
Privacy laws in your jurisdiction may provide you with different rights regarding your Personal Data, such as; (i) the right to access your Personal Data; (ii) the right of rectification of your Personal Data; (iii) the right to have your Personal Data erased (as long as we do not have a legitimate reason for retaining the data); (iv) the right to restrict processing of your Personal Data; (v) the right to object to the processing of your Personal Data; (vi) the right of data portability; (vii) the right to file a complaint to a supervisory authority in your jurisdiction; the right to non-discrimination and, (viii) the right to withdraw consent (if applicable)
(12) OPT-OUT RIGHT
Further, you may opt-out of the data collection related to our Website, as follows:
-
- you may set your browser to block all cookies, including cookies associated with our Services, or to indicate when a cookie is being set, by adjusting the privacy and security settings of your web browser. In these regards, please see the links provided under the Cookies section of this Policy.
- you may contact us (as detailed below), and we will make best efforts to assist you;
(13) CHILDREN’S PRIVACY
Our Services are not directed or intended for children, as defined under applicable law (i.e., thirteen (13) years of age if you are located in the US, sixteen (16) years of age if you are located in the EU or as otherwise defined under applicable laws in your jurisdiction). We do not knowingly collect or solicit information from children. If we later obtain actual knowledge that a user is considered as a child, we will take steps to immediately delete its Personal Data. We request that such individuals do not provide Personal Data through the Services. If you are under 18, please be sure to read the terms of this Policy with your responsible adult.
(14) TRANSFER OF DATA
We may store or process your information in the United States, EU or in other countries. If you are a resident of the European Economic Area (“EEA“) we will take appropriate measures to ensure that your information receives an adequate level of data protection upon its transfer outside of the EEA.
(15) DO NOT TRACK DISCLOSURE
This Website does not respond to Do Not Track signals. For more information about Do Not Track signals, please see http://www.allaboutdnt.com/.
(16) CONTACT US
If you wish to be provided with any other information related to our privacy practices, or you have any questions or concerns, please contact us at:
Livger LTD
Suite 1, Commercial House One, Eden Island
Company Number: 162608
(17) DATA PROTECTION OFFICER
If you have any requests regarding the data collected under this Policy, including without limitation, requests to exercise your rights regarding your Personal Data that we hold, please contact our Data Protection Officer: [email protected]
Please include your name and contact details (email or address) in order for us to be able to respond.