Introduction
This policy applies to your registration for our services on our site <livr.co> (Site) and your use of:
- the LIVR mobile application software (App) once you have downloaded a copy of the App onto your mobile telephone or handheld device (Device); and
- any of the services accessible through the App (Services).
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. The Site, our App and our Services are not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
This policy is provided in a layered format so you can click through to the specific areas set out below.
- IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- HOW IS YOUR PERSONAL DATA COLLECTED?
- HOW WE USE YOUR PERSONAL DATA
- DISCLOSURES OF YOUR PERSONAL DATA
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
- GLOSSARY
- DESCRIPTION OF CATEGORIES OF PERSONAL DATA
Important information and who we are
LIVR Limited (referred to as we, us and our in this policy) is the controller and is responsible for your personal data.
We have appointed a data privacy manager. If you have any questions about this privacy policy, please contact them using the details set out below.
Contact details
Our full details are:
- Full name of legal entity: LIVR Limited
- Email address: hello@livr.co
- Postal address: Harwood House, 43 Harwood Road, London, SW6 4QP
You have the right to make a complaint at any time to the Information Commissioner's Office (the ICO), the UK supervisory authority for data protection issues.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review.
This version was last updated on [16.10.2018]. It may change and, if it does, these changes will be notified to you by email and when you next start the App. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.
Third party links
Communications that we send you may, from time to time, contain links to and from third party websites. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services. Please check these policies before you submit any personal data to these websites or use these services.
The data we collect about you
We may collect, use, store and transfer different kinds of personal data about you as follows:
- Contact Data;
- Identity Data;
- Mailing Data;
- Marketing and Communications Data;
- Profile Data;
- Transaction Data;
- Usage Data.
We explain these categories of data below
We also collect, create, use and share aggregated data such as statistical or demographic data for any purpose (Aggregated Data). Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
How is your personal data collected?
We will collect and process the following data about you:
- information you give us. This is information (including Contact, Identity, Marketing and Communications and Transaction Data) you provide to us about yourself by filling in forms on the Site and our App or by corresponding with us (for example, by email or chat). It includes information you provide when you:
- register on the Site in order to use our App and Services;
- redeem a credit in order to watch a performance using our App;
- report a problem with the Site, the App or our Services.
If you contact us, we will keep a record of that correspondence.
- information we collect about you and your device. Each time you use our Site and our App, we will automatically collect personal data (including Usage Data). We collect this data using [cookies and tokens]. Please see our cookie policy for further details.
We may receive Aggregated Data from other sources (including third parties) but we will not receive any personal data about you from other sources.
Cookies
[We use cookies to distinguish you from other users of the Site and our App and to remember your preferences. This helps us to provide you with a good experience when you use the Site and our App and also allows us to improve them both.
A cookie is a small file of letters and numbers that we store on your Device or another device on which you access the Site. Cookies contain information that is transferred to your Device’s (or that other device’s) memory.
We use the following cookies:
- essential cookies. These are cookies that are required for the operation of the Site. They include, for example, cookies that enable you to log into secure areas of the Site;
- analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the Site when they are using it. This helps us to improve the way the Site works, for example, by ensuring that users are finding what they are looking for easily.
- functionality cookies. These are used to recognise you when you return to the Site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- targeting cookies. These cookies record your visit to the Site, the pages you have visited and the links you have followed. We will use this information to make the Site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
You may block cookies by activating the setting on the device which allows you to refuse the setting of all or some cookies. However, if you block all cookies (including essential cookies) you may not be able to access all or parts of the App or the Site.
Except for essential cookies, all cookies will expire after 2 years
How we use your personal data
We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:
- where you have consented before the processing;
- where we need to perform a contract we are about to enter or have entered with you;
- where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
- where we need to comply with a legal or regulatory obligation.
We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.
We will not share your personal data with any third party for marketing purposes.
Purposes for which we will use your personal data
|
Purpose/Activity |
Type of Data |
Lawful Basis for Processing |
|
To register your purchase of a new subscription (i.e. to register you on the Site as a new user) and to deliver Services (including managing payments and collecting money owed to us) |
Contact Identity Marketing and Communications Profile Transaction |
Performance of a contract with you Necessary for our legitimate interests (to allow us to take payment and to recover debts due to us) |
|
To deliver a headset to you (where you have requested one) |
Identity Mailing |
Performance of a contract with you |
|
To create Aggregated Data |
Usage
|
Necessary for our legitimate interests (to allow us to understand our userbase and how they use the Site and the App in order to further develop the Site, the App and our Services) |
|
To manage our relationship with you, including notifying you of changes to the Site, the App or any Services |
Identity Marketing and Communications Profile Transaction
|
Performance of a contract with you Necessary for our legitimate interests (to keep records updated and to analyse how customers use the Site, our App and our Services) Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions) |
|
To administer and protect our business as well as the Site and the App (including troubleshooting, data analysis and system testing) |
Identity Profile Usage |
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security) |
|
To deliver content and advertisements to you To make recommendations to you about goods or services which may interest you To measure and analyse the effectiveness of the advertising we send you (where applicable) To monitor trends so we can improve the Site, the App and our Services |
Identity Marketing and Communications Profile Usage
|
Necessary for our legitimate interests (to develop the Site, the App and our Services and to grow our business) |
Disclosures of your personal data
We will also share your personal data with the third parties set out below for the purposes set out in the [table above]:
- External Third Parties as set out in the [glossary];
- third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
International transfers
We do not transfer your personal data outside the European Economic Area (EEA).
Data security
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of the Site and our App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. We will collect and store personal data on your Device using application data caches.
Any payment transactions carried out by our chosen third-party provider of payment processing services will be encrypted.
We have put in place procedures to deal with any suspected personal data breach and – in the event of any actual or suspected personal data breach – will notify you and any applicable regulator when we are legally required to do so.
Data retention
Details of retention periods for different aspects of your personal data are set out below.
|
Type of Data |
Retention Period |
|
Mailing |
The earlier of:
assuming (in each case) we have no justification to keep processing the data. |
|
Contact Profile Transaction |
When we or you close your account for any other reason, assuming (in each case) we have no justification to keep processing the data.
|
|
Usage |
The earlier of:
assuming (in each case) we have no justification to keep processing the data. |
|
Identity Marketing and Communications Your email address |
18 months from the closure of your account, provided that you have not requested that we stop processing the data earlier. |
In some circumstances you can ask us to delete your data – see your legal rights below for further information.
In some circumstances, as described above. we will anonymise your personal data (so that it can no longer be associated with you), in which case we may use this information indefinitely without further notice to you.
Your legal rights
Under certain circumstances you have the following rights under data protection laws in relation to your personal data.
Please click on the links below to find out more about these rights:
- [Request access to your personal data.]
- [Request correction of your personal data.]
- [Request erasure of your personal data.]
- [Object to processing of your personal data.]
- [Request restriction of processing your personal data.]
- [Request transfer or your personal data.]
- [Right to withdraw consent.]
You also have the right to ask us not to continue to process your personal data for marketing purposes.
You can exercise any of these rights at any time by contacting us at hello@livr.co.
Glossary
Lawful basis
Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Third parties
External third parties
- Service providers (acting as processors):
- Philip Matthews (a freelancer) who provides IT and system administration services;
- Barry Mason (a freelancer) who provides IT and system administration services;
- Amazin Web Services, who provides hosting;
- Stripe, Inc. who provides payment processing services;
- Professional advisers (acting as processors):
- Artington Services Limited who provide legal services.
- Your legal rights
You have the right to:
- request access to your personal data (commonly known as a ‘data subject access request’). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;
- request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;
- request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you (if applicable) at the time of your request;
- object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
- request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- if you want us to establish the data’s accuracy;
- where our use of the data is unlawful but you do not want us to erase it;
- where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;
- request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you;
- withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Description of categories of personal data
- Contact Data: billing address and email address.
- Identity Data: first name and last name.
- Mailing Data: mailing address.
- Marketing and Communications Data: includes your preferences in receiving marketing from us and your communication preferences.
- Profile Data: includes your email address and password, credit redemptions (i.e. to watch a performance using our App), your interests, preferences, feedback and responses to communications (e.g. whether you opened emails from us and followed links in those emails).
- Transaction Data: includes details about payments to and from you and credit redemptions (i.e. to watch a performance using our App).
- Usage Data: includes details of your use of our App, including (but not limited to) the resources that you access.