Effective Date: September 22nd, 2022
- Who Collects Your Personal Information On Our Service?
We do. Under the GDPR, LTH is what is known as a “Controller” of the Personal Data that you provide us with. We collect information from you on the Service, and we are responsible for protection of your information.
- What Information Does LTH Collect?
- Requested Information. We collect certain personal information about you, which may be supplied when you register for the Service, when you create or update your account, when you use the Service, when you link your account with us to your social media account(s) via our optional integration, and otherwise when you submit such information. The types of PII that we collect and save include:
- Contact and account information, such as name, email address, phone number, payment account information (e.g. credit card number, cvv, and/or bank account numbers), username, and employment information; and
- Technical information, collected in our logs and via cookies. Such information may include standard web log entries that contain your device identifiers (including mobile devices) and information, operating system information, usage statistics, clickstream data, IP address, previous page URL, referring page URL and timestamps.
You may provide us with information when you interact with us through email, submit a review or a post, or through other use of the Service. We may retain such information in order to provide you with services, and you agree that we may share this information as needed with other users in order to resolve any issues that may arise between you and another user of the Service.
The Service may notify us when you have read an email that we sent to you.
The Service may also be integrated with third party social media platforms, such as Facebook and Instagram (“Platforms”). If you choose to interact with the Platforms through the Service, the Platforms may make additional Personal Information about you available to us.
- Non-personal Information. Non-personal information is non-personally identifiable or anonymous information about you, including but not limited to links and materials posted, the type of device you used and its operating system, browser information, the pages accessed most frequently, how pages and features are used, time spent on a page, when and how you use the App, search terms entered, and similar non-personal information.
Automatically tracking Internet Protocol (IP) addresses is one method of automatically collecting information about your activities online and information volunteered by you. An IP address is a number that is automatically assigned to your device whenever you surf the internet. Further, the Service may utilize web beacons, pixel tags, first party cookies (both session and persistent), embedded links, and other commonly used information-gathering tools.
If non-personal information is paired to any of your PII, we will treat the non-personal information as if it were also PII.
Part of the purpose of the Service is to share materials you make available. Anything you publicly post will not be considered personal information.
- Aggregate Information. We may also collect anonymous, non-identifying and aggregate information such as the type of browser you are using, the type of operating system you are using, the date and time of any request, language preference, referring site, and the domain name of your Internet service provider.
- Financial Information. Although it may appear that we collect financial information from you on the Service for the purposes of receiving your payment, it is actually collected and processed through a third-party service provider (“Payment Processor”) to process payments for the Service. The Payment Processor may collect financial information such as banking information or credit card number, name, CVV code or date of expiration, from you on the Service. We do not hold such financial information collected by the Payment Processor.
- Why Is My Information Being Collected?
We need to collect your PII so that we can provide the Service, respond to your requests for information, to integrate with Platforms at your option, to enforce our Terms of Service, and to process your requests to access, and make payment for or receive payment from, the Service. We also collect aggregate information to help us better design the Service. We collect log information for monitoring purposes to help us to diagnose problems with our servers, administer the Service, calculate usage levels, and otherwise provide services to you.
- How Do We Use the PII We Collect?
- We use the PII you provide for the purposes for which you have submitted it including:
- Internal Uses. We may use your PII to respond to your inquiries, fulfill your requests for information, track usage trends, conduct experiments, prevent fraud, develop and improve the Service and other offerings, and perform research and analytics.
- Creating and Maintaining Your User Account. We use your PII to create and maintain an account for you to allow you to purchase and use the Service.
- Paying for the Service. Your payment information is collected and processed through our Payment Processor.
- Social Media Integration. We may use your PII to, at your request, integrate your social media accounts with the Service, and to provide to you the social media features of the Service.
- Sharing with Vendors. We will share or disclose certain PII with Vendors who advertise their products or services on the Service, if you have viewed their products or profiles, and those of their competitors, if you have viewed them. Such transfers are subject to confidentiality obligations, including limitations on the use of such PII and its disclosure to just the marketing of their products and/or services.
- We may use anonymous information that we collect to improve the design and content of our Service, and to enable us to personalize your internet experience. We also may use this information in the aggregate to analyze how our Site is used, as well as to offer you programs or services.
- Do We Share Your PII?
We will not share your PII except: (a) for the purposes for which you provided it, including for the Service to function; (b) with your consent; (c) as may be required by law or as we think necessary to protect our organization or others from injury (e.g., in response to a court order or subpoena, in response to a law enforcement agency request, or when we believe that someone is causing, or is about to cause, injury to or interference with the rights or property of another); (d) with third party Vendors on the Service if you view their products or services, or those of a competing Vendor; or (e) subject to confidentiality obligations and limitations on the use and disclosure of PII, with persons or organizations with whom we contract to perform services for us, including the performance, or development of, aspects of the Service and other internal operations or business activities.
We may also share aggregate information with others, including affiliated and non-affiliated organizations.
Finally, we may transfer your PII to a third party, or our successor-in-interest, in relation to, or in the event of, a merger, acquisition, sale of all or substantially all of our assets, reorganization, recapitalization, bankruptcy, or other change of control. After such disclosure or transfer, the third party or successor in interest may use the information in accordance with applicable law.
- Are There Other Ways My Personal Data Could Be Shared?
You may elect to share certain personal information with individuals or with the public via your use of the Service. In this case, you will control such sharing via settings that we provide. For example, the Service may make it possible for you to publicly share information via Platforms such as Facebook, or Instagram. Be aware that when you choose to share information with friends, or with the public at large, you may be disclosing sensitive information, or information from which sensitive information can be inferred. Always use caution when sharing information through the Service. You understand and agree that we are not responsible for any consequences of your sharing of information through and beyond the Service.
- How Can You Access And Control Your Information?
After becoming a user of the Service, you may view, revise or edit certain personal information associated with you by logging into the Service and proceeding to your profile, or by sending an email to email@example.com.
For instructions on how you can further access your personal information that we have collected, or how to correct errors in such information, please send an email to firstname.lastname@example.org. We will promptly stop processing your information and remove it from our servers and database at any time upon your e-mail request to email@example.com, where required by law.
You may opt-out of any of the following by emailing us at firstname.lastname@example.org with “Opt-Out” in the subject line: sharing information with third parties; and receiving any promotional emails from LTH.
- How We Store and Protect Your Information.
- After receiving your PII, we will store it on our servers for future use. We have physical, electronic, and managerial procedures in place to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect. Unfortunately, no data transmission over the internet or data storage solution can ever be completely secure. As a result, although we take industry-standard steps to protect your information (e.g., strong encryption), we cannot ensure or warrant the security of any information you transmit to or receive from us or that we store on our or our service providers' systems.
- If you are accessing the Service from outside of the USA, you understand that your connection will be through and to servers located in the USA, and the information you provide will be securely stored in our servers and internal systems located within the USA.
- We store your PII until the earlier of (i) your PII no longer being necessary for the purposes for which it was being processed; (ii) our deletion of your PII in accordance with our data retention decisions as well as retention and other internal policies; or (iii) your request that we remove it from our servers, except in cases where we have the legal obligation, or authority, and we elect, to maintain that information. We store our logs and other technical records indefinitely.
- To enhance your online experience with us, our web pages may use "cookies." Cookies are text files that our web server may place on your hard disk to store your preferences. Cookies, by themselves, do not tell us your email address or other PII unless you choose to provide this information to us. Once you choose to provide PII, however, this information may be linked to the data stored in the cookie. Certain features of the Services may not function properly without the aid of cookies. LTH uses session cookies, which are necessary to allow you to seamlessly navigate from one page or area of the Site to another during your visit, and these are normally deleted when you close your web browser. We also use persistent cookies for your convenience so that you can log in faster, your preferences are remembered from visit to visit, and that you have an overall more convenient experience while visiting our Site.
- Our Service may use Google Analytics, a web analytics service provided by Google, Inc. ("Google"). For more information on how Google uses data when you use our Site or Service, please follow this link: https://policies.google.com/technologies/partner-sites. You may be able to opt-out of some or all of Google Analytics features by downloading the Google Analytics opt-out browser add-on, available at, https://tools.google.com/dlpage/gaoptout. Google may additionally use your information as described here, https://policies.google.com/technologies/partner-sites?hl=en-US. You may be able to opt-out of Google's collection and/or use of your information. Please visit Google's Ads Preferences Manager or the Google Analytics opt-out browser add-on for more information.
- We or our service providers may also use "pixel tags," "web beacons," "clear GIFs" or similar means (collectively, "Pixel Tags") in connection with some LTH Site pages and HTML-formatted email messages for purposes of, among other things, compiling aggregate statistics about website usage and response rates. A Pixel Tag is an electronic image, often a single pixel (1x1), that is ordinarily not visible to website visitors and may be associated with cookies on visitors’ hard drives. Pixel Tags allow us and our service providers to count users who have visited certain pages of the LTH Site, to deliver customized services, and to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted email messages, Pixel Tags can inform the sender of the email whether and when the email has been opened.
- As you use the internet, you leave a trail of electronic information at each website you visit. This information, which is sometimes referred to as "clickstream data”, can be collected and stored by a website's server. Clickstream data can reveal the type of computer and browsing software you use and the address of the website from which you linked to our Site. We may use clickstream data as a form of non-personally identifiable information to determine how much time visitors spend on each page of our Site, how visitors navigate through the Site, and how we may tailor our web pages to better meet the needs of visitors. We will only use this information to improve our Site, the App, and the Services.
- Do Not Track. At present, the Service does not specifically respond to browser do-not-track signals.
- Collection of Information by Others.
- ‘EEA’ Privacy Rights.
If you currently reside in the EEA, the GDPR applies to your PII and you are a Data Subject. The GDPR requires that we, in our capacity as a Controller, have a legal basis to process your PII.
- We process your PII under one or more of the following legal bases:
- Processing is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
- To perform the contract that we are about to enter with you (e.g., our Terms of Service);
- To comply with a legal obligation; and/or
- If we have your consent to do so, such consent capable of being revoked at any time.
- Under the GDPR, as a Data Subject you have certain rights. They are:
- The right to be informed. This is your right to be informed about what we are processing, why, and who else the data may be passed to.
- The right of access. This is your right to see what data about you is held by us.
- The right to rectification. This is the right to have your data corrected or amended if what is held is incorrect in some way.
- The right to be forgotten. This is the right to have your personal data to be deleted in the event that such data is no longer required for the purposes it was collected for, your consent for the processing of the data is withdrawn, or the data is being unlawfully processed.
- The right to restrict processing. This is the right to ask for a temporary halt to processing of your personal data, such as in the case where a dispute or legal case has to be concluded, or the data is being corrected.
- The right to data portability. This is the right to ask for your personal data to be provided to you in a structured, commonly used, and machine-readable format.
- The right to object. This is the right to object to further processing your personal data if such processing is inconsistent with the primary purposes for which it was collected.
- Rights in relation to automated decision making and profiling. This is the right to not be subject to a decision based solely on automated processing. The Service does not engage in automated decision making and profiling.
- Children and Young People’s Information.
We do not knowingly collect any information from any minors, and we comply with all applicable privacy laws including the Children's Online Privacy Protection Act (“COPPA”), and associated Federal Trade Commission (“FTC”) rules for collecting personal information from minors. Please see the FTC's website (www.ftc.gov) for more information. If you have concerns about this Site, wish to find out if your child has accessed our services, or wish to remove your child's personal information from our servers, please contact us at email@example.com. Our Site will not knowingly accept personal information from anyone under 13 years old in violation of applicable laws, without consent of a parent or guardian. In the event that we discover that a child under the age of 13 has provided PII to us, we will make efforts to delete the child’s information in accordance with the COPPA. If you believe that your child under 13 has gained access to our Site without your permission, please contact us at firstname.lastname@example.org.
- California Privacy Rights.
California law allows California residents to request information regarding our disclosures to third parties in the prior calendar year, if any, of their personally identifiable information. To make such a request, please contact us at email@example.com with "Request for Privacy Information" in the subject line. Please include enough detail for us to locate your file; at a minimum, your name, email, and username, if any. We will attempt to provide you with the requested information within thirty (30) days of receipt. We reserve our right not to respond to requests sent more than once in a calendar year, or requests submitted to an address other than the one posted in this notice. Please note that this law does not cover all information sharing. Our disclosure only includes information covered by the law.
- Our Contact Information
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