LIPSMM PRIVACY POLICY

If You have any questions about this Privacy Policy, please feel free to contact us by email at info@lipsmm.com

LIPSMM MARKETING AGENCY LTD (hereinafter referred to as “Provider”, “We”, “Us”) respects the privacy of the users of our Website and our products, services, or applications and understands how the protection of Personal Data is important, therefore the Provider has adopted this Privacy Policy (hereinafter referred to as “Privacy Policy”).

This Privacy Policy applies to the processing of Personal Data provided by the User, or that is otherwise became known to the Provider, as a result of the User’s use of the Provider’s Website located at https://www.lipsmm.com/ (hereinafter referred to as ”Website”).

This Privacy Policy lays out what kind of information relating to an identified or identifiable natural person we collect (hereafter referred to as “Personal Data”), the purpose of such data collection, how we use and disclose it, the users’ rights in relation to Personal Data, and how You can contact us about our privacy practices.

Please note we process the Personal Data in accordance with the EU General Data Protection Regulation No 2016/679 (hereinafter referred to as “GDPR”), other applicable EU regulations on data protection, The Law of Ukraine “On the protection of the Personal Data” (hereinafter referred to as “Law”) and other applicable Ukrainian legislation (collectively, hereinafter referred to as “Applicable Legislation”).

By continuing to use our Website, You confirm that You agree to the Privacy Policy.

Please note that our Website is not intended for minors below the age of 18 years and we do not knowingly collect data relating to minors.

The English language version of this Agreement constitutes an original, and therefore, shall prevail in case of any inconsistencies with translated versions, if any.

Any terms used in the Privacy Policy, that are not defined herein, shall have the meaning as defined in the Terms of Use of the Website.

IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY IN GENERAL OR ANY PART OF IT, PLEASE DO NOT USE OUR WEBSITE!

1. GENERAL PROVISIONS

1.1 For the purpose of the Applicable Legislation, in relation to our Websites and Users, the Provider, determines the purposes and means of the processing of Personal Data. The registered address of the Provider is 128 City Road, London, United Kingdom, EC1V 2NX and the official email is info@lipsmm.com.

1.2. If You are dissatisfied with the way we process Your Personal Data, You have the right to file a complaint with the supervisory authority for data protection issues. We would, however, appreciate the chance to deal with Your concerns before You approach the supervisory authority for data protection issues.

1.3. If You are a resident of an EEA Member State, You may find the information about supervisory authority in Your jurisdiction here.

1.4. This Privacy Policy could be revised to stay compliant with major privacy legislation. When we update this Privacy Policy, we will take appropriate measures to inform You, via publications on the Website, of all of the changes we make. We will obtain Your consent to any material changes if and where this is required by applicable data protection laws.

1.5. On the Website “buttons” and/or hyperlinks are included to promote or share web pages on social (media) networks or third-party websites such as Twitter, Instagram, Telegram, or YouTube. We do not supervise these networks and websites and are therefore not responsible for the processing of Your Personal Data by and through the parties behind those networks and websites. The use of these media is therefore at Your own risk. Before You make use of these third-party services, we recommend You read the privacy statements of those respective third parties.

1.6. You have the right to withdraw Your consent to the collection and processing of Your Personal Data at any time, but this withdrawal will not affect our right to process Personal Data, based on the consent given before withdrawal thereof, in part related to Personal Data received before such withdrawal.

2. THE DATA WE COLLECT

2.1. Depending on whether and how You use our Services, Website, Mobile Applications, or Chatbot, we may collect, use, store, and transfer different categories of Personal Data about You which are lied out below:

Identity Data: first name, last name, username, or similar identifier.
Contact Data: email address and telephone numbers.
Technical Data: sign-in history (date, OS, sign-in status, IP address, browser), internet connectivity data, internet protocol (IP) address, operator and carrier data, login data, browser type and version, device type, category and model, time zone setting and location data, language data, browser plug-in types and versions, operating system and platform, diagnostics data such as crash logs and any other data, and other information stored on or available regarding the devices You allow us access to when You visit the Website.
Usage Data: information about how You use the Website, the Services, Chatbot, and other offerings made available by us, including
- device download time,
- install time,
- registration time,
- interaction type and time,
- event time, name, and source.
Marketing Data: Your preferences in receiving marketing from third parties or Us.

2.2. Certain types of sensitive Personal Data are subject to additional protection under the Applicable Legislation (hereafter referred to as “Special categories of Personal Data”). The Special categories of Personal Data are::

Personal data revealing racial or ethnic origin.
Political opinions.
Religious or philosophical beliefs.
Trade union membership.
Genetic data and biometric data are processed for the purpose of uniquely identifying a natural person.
Data concerning health.
Data concerning a natural person’s sex life or sexual orientation.

We do not collect, store, or process any data, that constitutes the Special categories of Personal Data.

3. COLLECTION AND USAGE OF PERSONAL DATA (PURPOSES AND LEGAL BASIS)

3.1. We use different methods to collect Personal Data about our users and visitors. Usually, You personally provide us with Your data by directly interacting with us when You:

visit our Website;
make a communication request using our Website;
request marketing materials to be sent to You, (i.e. subscribing to our newsletters);
engage in a competition, promotion, or survey, including through social media channels;
give us feedback or contact us.

3.2. As You interact with us via our Website, we will automatically collect Technical Data and Usage Data about Your equipment, browsing actions, and patterns. We collect this Personal Data by using cookies and other similar technologies. We may also receive Technical Data and Marketing Data about You if You visit other websites employing our cookies. You may find more information about how we use cookies through the Cookie Policy.

3.3. We will use Your Personal Data exclusively in case one of the conditions listed below is met:

You have given explicit consent to the processing;
it is necessary for the performance of a contract, that You have entered with the Provider;
it is necessary for compliance with a legal obligation to which we may be or are subject(ed); and
it is necessary for the performance of a task carried out in the public interest
it is necessary for the purposes of the legitimate interests pursued by us.

3.5. We will use Your Personal Data for the purposes, laid out in Table #1:

Table #1

PURPOSE	CATEGORIES	LEGAL BASIS
To process with collaboration with You and to contact You	· Identity Data · Contact Data · Technical Data · Marketing Data	Article 6 (1)(a)(b) of the GDPR Article 11, paragraph 1, clauses 1,3 of the Law
To keep our records updated and to study how customers use our products/services	· Identity Data · Contact Data · Marketing Data	Article (1)(a)(f) of the GDPR Article 11, paragraph 1, clauses 1,6 of the Law
To gather market data for studying customers’ behavior including their preferences, interest, and how they use our products/services, determining our marketing campaigns, and growing our business	· Identity Data · Contact Data · Usage Data · Marketing Data	Article 6 (1)(f) of the GDPR Article 11, paragraph 1, clause 6 of the Law
To deliver relevant website content and advertisements to You	· Identity Data · Contact Data · Usage Data · Technical Data · Marketing Data	Article 6 (1)(a)(f) of the GDPR Article 11, paragraph 1, clauses 1,6 of the Law
To improve our Website, products/services, marketing, Your user experience	· Usage Data · Technical Data	Article 6 (1)(a)(f) of the GDPR Article 11, paragraph 1, clauses 1,6 of the Law
To use the services of social media platforms or advertising platforms some of which will use the Personal Data they receive for their own purposes, including marketing purposes	· Usage Data · Technical Data	Article 6 (1)(a) of the GDPR Article 11, paragraph 1, clause 1 of the Law
To administer and protect our Website in order to provide network security and prevention of the fraud	· Identity Data · Contact Data · Technical Data	Article 6 (1)(f) of the GDPR Article 11, paragraph 1, clause 6 of the Law

4. DATA SUBJECT RIGHTS

4.1. You have the following rights:

to receive confirmation as to whether or not Personal Data concerning You is being processed, and access Your stored Personal Data, together with supplementary information;
to receive a copy of Personal Data You directly volunteer to us in a structured, commonly used, and machine-readable format;
to request rectification of Your Personal Data that is in our control;
to request the erasure of Your Personal Data;
to object to the processing of Personal Data by us;
to request to restrict the processing of Your Personal Data by us;
to lodge a complaint with a supervisory authority.

4.2. However, please note that these rights are not absolute, and may be subject to our own legitimate interests under this Privacy Policy and regulatory requirements. If You wish to exercise any of the aforementioned rights or receive more information, please contact us by email at info@lipsmm.com.

4.3. The statutory period under the Applicable Legislation for us to reply to a legitimate request is one month. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests.

4.4. Please note that we may request that You provide some details necessary to verify Your identity when You request to exercise a legal right regarding Your Personal Data.

5. DISCLOSURE OF PERSONAL DATA

5.1. We share Your Personal Data with our third-party service providers, agents, subcontractors, and other associated organizations, our group companies, and affiliates (as described below) in order to complete tasks and provide the Services to You on our behalf.

5.2. We may share Your Personal Data with:

companies that we plan to merge with or be acquired by (if such a combination occurs, we will notify You and will require that the newly combined entity follow this Privacy Policy with respect to Your Personal Data);
law enforcement, government officials, or other third parties when we are compelled to do so by a subpoena, court order, or similar legal procedure; or we believe in good faith that the disclosure of Personal Data is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of any of our policies;
identity verification agencies to undertake required verification checks;
fraud or crime prevention agencies to help fight against crimes including fraud, money laundering, and terrorist financing;
Uur vendors and agents, hired by Us.

5.3. Our Website may, from time to time, contain links to the websites or services of our partner networks, advertisers, transaction processors, etc. If You follow a link to any of these websites or services, please note that these websites and any services that may be accessible through them have their own privacy policies and that we are not responsible or liable for any of these policies or for any information, including Personal Data that may be collected through these websites or services, such as contact and location data. Please check these policies before You submit any information or Personal Data to these websites or use these services.

6. INTERNATIONAL TRANSFER

6.1. Many of our external third parties are based outside the European Economic Area (“EEA”) and/or Ukraine so their processing of Your Personal Data will involve a transfer of data outside the EEA and/or Ukraine.

6.2. Whenever we transfer Your Personal Data out of the EEA and/or Ukraine, we guarantee that a similar respective degree of protection is afforded to it, which ensures the implementation of at least one of the following safeguards:

the country to which we transfer Your Personal Data has been deemed to provide an adequate level of protection for Personal Data by the European Commission and/or the Government of Ukraine respectively;
a specific contract signed with such a third party, which includes “Standard data protection clauses” (as defined in GDPR) approved by the European Commission which gives safeguards to the processing of Personal Data.

7. SECURITY OF PERSONAL DATA

7.1. We implemented a number of security measures to ensure that Your data is not lost, abused, or misused. We also authorize access to Your data only for those employees or contractors who require it to fulfil their job or service responsibilities.

7.2. Please note that the transmission of data (including communications by email) over the Internet or other publicly accessible networks is not completely secure. We are not liable for the security of any data You are transmitting over the Internet. We are not responsible for the distribution and use of Your Personal Data that You have made visible to other users.

8. DATA RETENTION

8.1. We consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of Your Personal Data, the purposes for which we process Your Personal Data, and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements when determining the appropriate retention period for Personal Data.

We store and process Your data only as long as it is necessary for the purpose for which it was obtained.

8.2. The following factors will be considered while determining how long we need to retain Your Personal Data:

if we reasonably believe there is a prospect of litigation with respect to our relationship with You or if we consider that we need to keep information to defend possible future legal claims;
to comply with any applicable legal and/or regulatory requirements with respect to certain types of Personal Data:
if the data is needed for audit purposes and so forth;
in accordance with relevant industry standards or guidelines.

8.3. We will erase Your Personal Data without undue delay where one of the following grounds applies:

the Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
You withdraw consent on which the processing is based and where there is no other legal ground for the processing;
You object to the processing and there are no overriding legitimate grounds for the processing;
the Personal Data has been unlawfully processed;
the Personal Data has to be erased for compliance with a legal obligation placed upon us by the Relevant Legislation.

9. ANNEXES

Documents lied out below shall constitute an integral part of this Privacy Policy:

Cookie Policy

LIPSMM COOKIE POLICY