Effective date: 28th February 2022
We take data protection very seriously and abide by the EU General Data Protection Regulation (GDPR), CCPA, NZ Privacy Act 2020, Australia Privacy Act 1988, any Japanese Privacy laws and any other relevant privacy laws that govern our jurisdiction.
PERSONAL INFORMATION WE COLLECT
Personal information you provide to us. Personal information you may provide to us through the Service or otherwise includes:
- Contact data, personal or business contact information such as your first and last name, email and mailing addresses, phone number and professional title.
- Registration data, such as information that you provide to register for an account including your date of birth.
- Profile data, such as your username and password that you may set to establish an online account with us and your interests and preferences.
- Communications, such as information you provide when you contact us with questions, feedback, survey responses, or otherwise correspond with us,
- Marketing data, such as the email address or contact details that we use to send marketing communications and your preferences for receiving communications about our activities, events, sweepstakes and contests.
- Purchase data, including your order history and information needed to process and fulfill your order, including order details, billing address.
Data from other sources. We may also collect information about you from:
- Business partners, such as advertising and joint marketing partners.
- Data providers, such as information services and data licensors.
- Public sources, such as blogs, forums or social media platforms.
Automatic Collection. We and our service providers may automatically log information about you, your computer or mobile device, and your activity occurring on or through the Sites, such as:
- Device data, such as your computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, the website you visited before browsing our site, and general location information such as city, state or geographic area.
- Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
Cookies and similar technologies. Some of our automatic data collection is facilitated by cookies and similar technologies.
Referrals. Users of the Service may have the opportunity to refer friends or other contacts to us. If you are an existing user, you may only submit a referral if you have permission to provide their contact information to us so that we may contact them.
HOW WE USE YOUR PERSONAL INFORMATION
Service delivery. We may use your personal information to:
- provide, operate and improve the Service;
- establish and maintain your account on the Service;
- communicate with you about the Service, including by sending you announcements, updates, security alerts, and support and administrative messages;
- provide customer support and maintenance for the Service;
- facilitate your login to the Sites via third party platforms, such as Google and Facebook; and
- enable security features of the Sites, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in.
Direct Marketing. We may use your personal information to send you LiNeo-related marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in the Your Choices section below.
For research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business.
To create anonymous data. We may create aggregated, de-identified or other anonymous data records from your personal information and other individuals whose personal information we collect. We make personal information into anonymous data by excluding information (such as your name) that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
To comply with laws and regulations. We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
For compliance, fraud prevention and safety. We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) audit our internal processes for compliance with legal and contractual requirements; (c) enforce the terms and conditions that govern the Service; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity, including cyber attacks and identity theft.
With your consent. In some cases we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
HOW WE SHARE YOUR PERSONAL INFORMATION
Service providers. Companies and individuals that provide services on our behalf or help us operate the Service or our business (such as service fulfillment, customer support, hosting, analytics, email delivery, marketing, database management services, returns processing and risk and fraud mitigation).
Advertising partners. Third party advertising companies that collect information about your activity on the Site and other online services to help us advertise our services, and/or use hashed customer lists that we share with them to deliver ads to them and similar users on their platforms.
Third party platforms. Social media and other third party platforms that you connect to the Service, such as when you use options to access the Service by logging into a social media platform. Please note, we do not control the third party’s use of your personal information.
The public. Other users of the Service and the public, when you disclose personal information for public use. We do not control how other users or third parties use any personal information that you make available to them. Please be aware that any information you post publicly can be cached, copied, screen captured or stored elsewhere by others (e.g., search engines) before you have a chance to edit or remove it.
Professional advisors. Professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate to comply with law or for the compliance, fraud prevention and safety purposes described above.
Business transferees. We may sell, transfer, or otherwise share some or all of your personal information in connection with or during negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets, or in the event of an insolvency, bankruptcy, or receivership.
In this section, we describe the rights and choices available to all users.
Access or update your account information. If you have registered for an account with us, you may review and update certain personal information in your account profile by logging into the account.
Opt out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions located at the bottom of the email. You may continue to receive service-related and other non-marketing emails. If you receive marketing text messages from us, you may opt out of receiving further marketing text messages from us by replying STOP to our marketing message.
Cookies. Most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings.
Advertising Choices. You may opt-out of interest-based advertising.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com
Privacy settings and location data. Users of our App can disable our access to their device’s precise geo-location in their mobile device settings.
Choosing not to share your personal information. If you do not provide information that we need to provide the Service, we may not be able to provide you with the Service or certain features. We will tell you what information you must provide to receive the Service when we request it.
Third-party platforms or social media networks. If you choose to create an account through or connect the Service with another third-party platform, you may have the ability to limit the information that we may obtain from the third-party at the time you log in to the Service using the third-party’s authentication service or otherwise connect your account. You may also be able to control your settings through the third-party’s platform or service after you have connected your accounts.
OTHER SITES, MOBILE APPLICATIONS AND SERVICES
The Sites may contain links to other websites and online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or online services that are not associated with us. We do not control third party websites or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites and online services you use.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Services. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/
The security of your personal information is important to us. We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.
INTERNATIONAL DATA TRANSFERS
LiNeo is headquartered in Japan and may have service providers in other countries. The data can transfer to other countries.
The Service is not intended for use by children under 18 years of age, and we do not knowingly collect information about children under age 18 through the Service. If we learn that we have collected personal information of a child without the consent of the child’s parent or guardian as required by law, we will delete it.
DATA PROTECTION RIGHTS UNDER THE GDPR
LiNeo is committed to ensuring fair and transparent processing. That is why it is important to us that data subjects can not only exercise their right to object but also the following rights where the respective legal requirements are satisfied:
- Right to information, Art. 15 of the GDPR
- Right to correction, Art. 16 of the GDPR
- Right to deletion (“Right to be forgotten”), Art. 17 of the GDPR
- Right to limit processing, Art. 18 of the GDPR
- Right to data transmissibility, Art. 20 of the GDPR
- Right to object, Art. 21 of the GDPR
To exercise your right, please contact us as indicated in the "Contact Us" section below.
In order to be able to process your request, as well as for identification purposes, please note that we will use your personal information in accordance with Art. 6 para. 1 (c) of the GDPR.
You also have the right to lodge a complaint with a supervisory authority pursuant to Art. 77 GDPR in combination with Section 19 GDPR.
We are required by the California Consumer Privacy Act (“CCPA”) to provide to California residents an explanation of how we collect, use and share their Personal Information, and of the rights and choices, we offer to California residents concerning that Personal Information.
Your California privacy rights. The CCPA grants California residents the following rights. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.
- Information. You can request information about how we have collected, used and shared and used your Personal Information during the past 12 months.
- The categories of Personal Information that we have collected.
- The categories of sources from which we collected Personal Information.
- The business or commercial purpose for collecting and/or selling Personal Information.
- The categories of third parties with whom we share Personal Information.
- Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third party recipient.
- Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient.
- Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
- Deletion. You can ask us to delete the Personal Information that we have collected from you.
You are entitled to exercise the rights described above free from discrimination in the form of legally prohibited increases in the price or decreases in the quality of our Service.
How to exercise your California rights. You may exercise your California privacy rights described above as follows:
- Right to information, access and deletion. You can request to exercise your information, access and deletion rights, by emailing firstname.lastname@example.org.We reserve the right to confirm your California residence to process your requests and will need to confirm your identity to process your requests to exercise your information, access or deletion rights. As part of this process, government identification may be required. Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued identification. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
- Request a list of third party marketers. California’s “Shine the Light” law (California Civil Code § 1798.83) allows California residents to ask companies with whom they have formed a business relationship primarily for personal, family or household purposes to provide certain information about the companies’ sharing of certain personal information with third parties for their direct marketing purposes during the preceding year (if any). You can submit such a request by sending an email to email@example.com with “Shine the Light” in the subject line. The request must include your current name, street address, city, state, and zip code and attest to the fact that you are a California resident.
We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
Sharing your personal information
We do not sell, trade, or rent Users personal identification information to others in accordance with the CCPA. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above.
NZ Privacy Act 2020 - Legal rights around managing your privacy
We are committed to protecting the security of your personal information and we take all reasonable precautions to protect it from Privacy Breaches, namely:
- unauthorised or accidental access, disclosure, alteration, loss, destruction of your personal information; and
- actions which prevent us from accessing your personal information on a temporary or permanent basis.
If your personal information is subject to a privacy breach which causes or is likely to cause serious harm, we will notify you and the Privacy Commissioner in accordance with our obligations under the Privacy Act 2020.
Your personal information is transferred to our third-party service providers in overseas countries. By providing your personal information to us, you acknowledge that some third party service providers may be located in countries which do not have the same level of privacy laws as New Zealand and you consent to the transfer of your personal information in these circumstances.
If you wish to access or change your personal information, we may ask you for additional information to confirm your identity and for security purposes, in particular before disclosing personal information to you.
You can access your information by emailing us at firstname.lastname@example.org. Subject to legal and other permissible considerations, we will make every reasonable effort to respond to your request promptly or inform you if we require further information in order to fulfil your request.
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
Please contact us at email@example.com if you would like to access your information, and we will comply with any request to the extent required under applicable law.
Australia Privacy Act
Accessing and updating or correcting your information and how to submit a complaint.
Subject to the exceptions set out in the Privacy Act and other applicable privacy laws, you may request to access, update or correct the personal information we hold about you. We will require you to verify your identity and to specify the information that you wish to access, update or correct. A fee may be charged for providing access however we will advise you of the likely cost in advance.
Subscribers or members of our websites will generally be able to access, update and correct their membership and contact details online.
We request that you keep your information as current as possible so that we may continue to improve our service to you.
If you wish to access, update or correct any personal information that we hold about you, or if you have any questions or would like to submit a complaint about how we collect, use, disclose, store or otherwise handle your personal information, you can contact the department that collected your personal information in the first instance, or write to our Privacy Officer at the contact details below. We will acknowledge your complaint promptly and use best endeavours to work with you to resolve your complaint.
Effective date: 1st February 2022
What are cookies?
Cookies do not contain any personal or confidential information about you.
The types of cookies that we may use include:
· Session cookies
Session cookies last only for the duration of your visit and are deleted when you close your browser. These facilitate various tasks such as allowing a website to identify that a user of a particular device is navigating from page to page, supporting website security or basic functionality.
· Persistent cookies
Persistent cookies last after you have closed your browser, and allow a website to remember your actions and preferences. Sometimes persistent cookies are used by websites to provide targeted advertising based upon the browsing history of the device.
We use persistent cookies to allow us to analyze users visit to our site. These cookies help us to understand how customers arrive at and use our site so we can improve the overall service.
· Strictly necessary cookies
These cookies are essential in order to enable you to move around the website and use its features, and ensuring the security of your experience. Without these cookies services you have asked for, such as applying for products and managing your accounts, cannot be provided. These cookies don’t gather information about you for the purposes of marketing.
· Performance cookies
These cookies collect information about how visitors use a web site, for instance which pages visitors go to most often, and if they get error messages from web pages. All information these cookies collect is only used to improve how a website works, the user experience and to optimize our advertising. By using our websites you agree that we can place these types of cookies on your device, however you can block these cookies using your browser settings.
· Functionality cookies
These cookies allow the website to remember choices you make (such as your username). The information these cookies collect is anonymized (i.e. it does not contain your name, address etc.) and they do not track your browsing activity across other websites. By using our websites you agree that we can place these types of cookies on your device, however you can block these cookies using your browser settings.
· Targeting cookies
These cookies collect several pieces of information about your browsing habits. [They are usually placed by third party advertising networks]. They remember that you have visited a website and this information is shared with other organizations such as media publishers. These organizations do this in order to provide you with targeted adverts
more relevant to you and your interests.
· Third party cookies
You can control and/or delete cookies as you wish – for details, see aboutcookies.org. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit our website or use our Platform and some services and functionalities we offer may not work.
To restrict or handle cookies, please see the ‘Help’ section of your internet browser.
For any further information, please contact us firstname.lastname@example.org