Last updated July 26, 2020
We’ve added a section on how our partners use your data and what options you have.
Thank you for choosing to be part of our community at Luuply (“Company”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at [email protected].
1. What information do we collect?
Personal information you disclose to us
In short: We collect personal information that you provide to use such as name, address, contact information, passwords and security data, payment information, and social media login data.
We collect personal information that you voluntarily provide to us when registering for the Services expressing an interest in obtaining information about us and our services, when participating in activites on the Services (such as posting messages in our online forums) or otherwise contacting us.
The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make and the products and features you use. The personal information that we collect can include the following:
- Publically available personal information. We may collect your real name, alias, postal address, unique personal identifiers, email address, account name.
- Private personal information. We may collect limited education information in order to comply with certain regulations.
- Personal information provided by you. We collect app usage, and other similar data.
- Credentials. We collect passwords and similar security information used for authentication and account access.
- Social media login data. We provide you with the option to register using social media account details, like your Facebook, Twitter, Google, or other social media account. If you choose to register this way, we will collect the information described in the section called “HOW DO WE HANDLE YOUR SOCIAL LOGINS” below.
Information automatically collected
In short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not and cannot reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system and version, language preferences, referring URLs, device name, country, location, information on how and when you use our services, and other technical information. This information is primarily need to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
Online Identifiers. We collect applications, tools, and protocols, such as IP addresses, cookie identifiers, or others such as the ones used for analytics and marketing, and other similar data.
2. How do we use your information?
In short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.
We use personal information collected via our Services for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
- To facilitate account creation and logon processes. If you choose to link your account with us to a third party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon processes for the performance of the contract.
- To protect our Services. We may use your information as part of our efforst to keep our Services safe and secure, like fraud-monitoring and prevention.
- To enable user-to-user communication.
- To manage user accounts and to keep them in working order
- To deliver services to you.
- To respond to user inquiries, and to offer support to users.
3. How do we handle your social logins?
In short: If you choose to register or log into our services using a social media account, we may have access to certain information about you.
Our Services offer you the ability to register and login using your third party social media account details. Where you choose to do this, we will receive certain profile about you from your social media provide. The profile information we receive may vary depending on the social media provide concerned, but will often include your name, e-mail address, friends list, profile picture, as well as other information you chose to make public.
4. What about links to external sites?
We have no control over, and assume no responsibility for the content, privacy policies or practices of any third party sites, products or services.
The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security. If you wish to learn more about secure ways to connect to our web services, please email us at [email protected].
Ads appearing on our website may be delivered to users by advertising partners, who may set cookies. These cookies allow the ad server to recognize your computer each time they send you an online advertisement to compile information about you or others who use your computer. This information allows ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you.
You can see how Google uses information from Luuply to carry out its services to you here.
To enrich and perfect your online experience, Luuply uses “Cookies”, similar technologies and services provided by others to display personalized content, appropriate advertising and store your preferences on your computer.
8. Protection of Certain Personally-Identifying Information
Luuply discloses potentially personally-identifying and personally-identifying information only to those of its employees, contractors and affiliated organizations that (i) need to know that information in order to process it on Luuply’s behalf or to provide services available at Luuply’s website, and (ii) that have agreed not to disclose it to others. Some of those employees, contractors and affiliated organizations may be located outside of your home country; by using Luuply’s website, you consent to the transfer of such information to them. Luuply will not rent or sell potentially personally- identifying and personally-identifying information to anyone. Other than to its employees, contractors and affiliated organizations, as described above, Luuply discloses potentially personally-identifying and personally-identifying information only in response to a subpoena, court order or other governmental request, or when Luuply believes in good faith that disclosure is reasonably necessary to protect the property or rights of Luuply, third parties or the public at large.
If you are a registered user of https://luuply.com and have supplied your email address, Luuply may occasionally send you an email to tell you about new features, solicit your feedback, or just keep you up to date with what’s going on with Luuply and our products. We primarily use our blog to communicate this type of information, so we expect to keep this type of email to a minimum. If you send us a request (for example via a support email or via one of our feedback mechanisms), we reserve the right to publish it in order to help us clarify or respond to your request or to help us support other users. Luuply takes all measures reasonably necessary to protect against the unauthorized access, use, alteration or destruction of potentially personally-identifying and personally-identifying information.
9. CCPA Privacy Notice
Information We Collect
We collect 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 or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
A real name, alias, postal address, unique personal
identifier, online identifier, Internet Protocol address, email
address, account name, or other similar identifiers.
B. Personal information
categories listed in the
Records statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, physical characteristics or description, address, telephone number, education, employment, or any other financial information, medical information, or health
insurance information. Some personal information included
in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.
Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental ability, 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).
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or
consuming histories or tendencies.
E. Biometric information.
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
F. Internet or other similar network activity.
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
G. Geolocation data.
Physical location or movements.
H. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information.
I. Professional or employment-related information.
Current or past job history or performance evaluations.
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)).
Educational 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.
K. Inferences drawn from other personal information.
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Personal information does not include:
- Publically available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from our users or their agents. For example, from form data that our users provide to us directly to the services for which they engage us.
- Indirectly from our users or their agents. For example, through information we collect from our users in the course of providing services to them.
- From third-parties that interact with us in connection with the services that we perform. For example, from advertising partners.
Use of Personal Information
We may use or diclose the personal information that we collect for one or more of the following business purposes:
- To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in order for us to prepare a tax return, we will use that information to prepare the return and submit it to the applicable taxing authorities.
- To provide you with information, products or services that you request from us.
- To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
- To improve our website and present its contents to you.
- For testing, research, analysis, and product development.
- As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party for a legitimate 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.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category A: Identifiers
Category B: California Customer Records personal information categories
Category C: Protected classification characteristics under California or federal law
Category F: Internet and other similar network activity
Category G: Geolocation data
We disclose your personal information for a business purpose to the following categories of third parties:
- Our affiliates
- Service partners
- Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
In the preceding twelve (12) months, we have not sold any personal information.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categoreis that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. This may be known in your jurisdiction as the “right to be forgotten”. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for you by law.
- Comply with the California Electronic Communications Privacy Act (California Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
- Complete an internal investigation into fraudulent or malicious behavior that violates our Terms and Conditions of Use for End Users.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either emailing us at [email protected].
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
10. GDPR Privacy Notice
This policy explains how Luuply uses the personal data we collect from you when you use our website, and outlines your European Union General Data Protection Regulation rights.
How do we store your data?
Luuply securely stores and processes your data using different “cloud” computing providers, which include, but are not limited to, Amazon Web Services (AWS), Microsoft Azure, and Cloudflare. In the interest of data security, AWS and Microsoft do not publish the exact locations of their datacenters. We expect our cloud computing providers to uphold a high level of security, including physical and logical security measures. Additionally, we enforce certain protocols, including HTTP/2 and SSL on all of our systems.
Luuply keeps active user data indefinitely. If you are inactive for at least five years, we may request to remove some of your select user data. If we do not receive a timely response or you allow us to, we will securely remove all of your profile data from our production systems, including from any databases. Individual user reviews or user-submitted material will be kept indefinitely unless we receive a verifiable request to remove such material.
What are my data protection rights?
Luuply wants to make sure that you’re fully aware of all of your data protection rights. Every user is entitled to the following:
- The right to access – you have the right to request from Luuply, copies of your personal data. You also have the right to request that Luuply transfer the data that we have collected to another organization, under certain conditions. This may be known in some areas as data portability.
- The right to rectification – you have the right to request that Luuply correct any information you believe to be inaccurate. You also have the right to request Luuply complete information you believe is incomplete.
- The right to erasure – you have the right to request that Luuply erase your personal data, under certain conditions.
- The right to restrict processing – you have the right to request that Luuply restrict the processing of your personal data, under certain conditions.
- The right to object to processing – you have the right to object to Luuply’s processing of your personal data.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at [email protected].
11. LGPD Privacy Notice
This policy explains how Luuply uses the personal data we collect from you when you use our website, and outlines your Lei Geral de Proteção de Dados (“LGPD”) rights.
How does Luuply use your personal information?
How does Luuply protect your personal information?
Luuply has strict data processing standards, and we employ several proactive and defensive strategies to prevent the release of personal and sensitive information. Luuply securely stores and processes your data using different “cloud” computing providers, which include, but are not limited to, Amazon Web Services (AWS), Microsoft Azure, and Cloudflare. We expect our cloud computing providers to uphold a high level of security, including physical and logical security measures. Additionally, we enforce certain protocols, including HTTP/2, TLS 1.2 and SSL on all of our systems.
How long does Luuply keep my personal information?
Luuply keeps your personal information indefinitely.
What rights do I have under the LGPD?
You have the right to knowledge (what data we collect, and what data we possess on you), the right to rectification (to correct erroneous data), and the right to be forgotten (for Luuply to erase your personal data, under certain conditions). To exercise these rights, contact the data officer by emailing [email protected].
If you make a request, we have one month to respond to you. If you would like to exercise any of your rights, please contact us at [email protected].
12. Further Information