Questions regarding this statement should be directed to the site coordinator at email@example.com.
If you have any concerns or feel that there are certain problems or issues relating to compliance with the policies outlined in this privacy statement, please submit a report at firstname.lastname@example.org.
If you reside in the European Union (“EU”), United Kingdom, Lichtenstein, Norway or Iceland, you may have additional rights with respect to your Personal Data, as further outlined below. These rights may include rights under the EU’s General Data Protection Regulation (“GDPR”), if you are a resident of the EU, United Kingdom, Lichtenstein, Norway or Iceland.
Third Party Websites
Luxand does not control the information collection and distribution policies on Internet domains other than those Internet domains that are under the control of Luxand itself. When you are on the Luxand Websites, you may be directed to other sites that are beyond our control. These other sites may independently collect data, solicit personal information, or send their own “cookies” to you. Luxand is not responsible for any use of the information including click-stream data created when using such third party sites.
This Website may also contain advertising and other links to other Websites. Please be aware that we are not responsible for the privacy practices or content of those other sites. Also we do not send random marketing emails to personal email addresses (spam). This Website may contain hyper links to external Websites owned and operated by third parties. Luxand has no control over or association with such third party sites and Luxand is not responsible for the accuracy, completeness and quality of the information contained within them. Any and all contents on these external Websites do not reflect products, services or information provided by Luxand. You should direct any concerns regarding any external link to the site administrator or webmaster of such site.
This Website may be subject to the laws of various jurisdictions, including the laws of the United States of America, Russian Federation and European Union and other jurisdiction because the access to our Website may use internet traffic of different jurisdictions, including without limitation the United States of America and European Union. Luxand will disclose personally identifiable information without your permission when required by law, or in good faith belief that such action is necessary to investigate or protect against harmful activities to Luxand guests, visitors, associates, or property (including this Website), or to others. As mentioned above, laws related to personal identifiable information vary by country. For example, personally identifiable information collected in the European Union and its Member States is subject to the EU Directives concerning personal data, privacy and electronic communications, including but not limited to Directive 2002/58/EC of the European Parliament and of the Council of 12 July 2002 concerning the processing of personal data and the protection of privacy in the electronic communications sector and Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and the subsequent legislation adopted in the EU Member States.
B. COLLECTED INFORMATION
As a visitor to the Website, we may collect both personal and non-personal information about you. Non-personal information includes anonymous information such as demographic data. Under all circumstances, we will only collect the information deemed reasonably necessary to fulfill your online requests and our legitimate business objectives. Below for your review is a short description of the information that we may collect from you:
· Personal Information is information that can be used to identify you such as your name, address, telephone number, or email address. We do not collect any Personal Information about you unless you choose to provide it to us by, for example, filling out and submitting an online form. If you choose not to provide Personal Information, you may be unable to use certain features on our Websites.
· Demographic information is anonymous information such as your age, date of birth, gender, hobbies, interests, zip/postal code or country. If demographic information is collected for an activity that also requires Personal Information, we may combine the demographic information with your Personal Information. Combining data allows us to customize the notices we send you and the content we provide you according to your interests and preferences. Demographic information is not considered Personal Information unless it is linked to Personal Information about a specific user. If you choose not to provide certain demographic information, you may not be able to use certain features on our Websites.
· Aggregate information is anonymous data about individuals that is grouped together to study a group or category of services or users. Aggregate information is not considered Personal Information unless it is linked to Personal Information about a specific user.
C. COLLECTION AND USE OF PERSONAL INFORMATION
We request Personal Information and demographic information to respond to your requests and provide services to you such as: sending email newsletters; displaying targeted advertising (for example, in Facebook); participating in online; processing orders through our online store; setting up repair orders; and sending email correspondence. Each category below describes how we handle the requested information.
Browsing the Website
When you use the Website, we or third parties, authorized by us, may also collect certain technical and routing information about your computer to facilitate your use of the Website and our services. When you surf the Internet, your Internet browser (such as Mozilla Firefox or Microsoft Internet Explorer) automatically transmits some information to us every time you access content on one of our internet domains within the Website. Examples of such information include the URL of the Web page you were just on, the IP (or Internet Protocol) address of the computer you are using, or the browser version you are using to access our site. All of this information may be collected by us and used to help improve our offerings to you.
If you purchase goods or services through our online store or elsewhere on our Websites, you may need to provide a valid credit card number, expiration date and credit card security code, in addition to your name, mailing and billing addresses, phone number and email address. Please note that you must be over the age of eighteen (18) to place orders online. All financial information is transmitted through the use of encryption, i.e. a Secure Socket Layer (SSL) protocol via our secure server.
Email Correspondence and Other Communication
We may respond to your email correspondence and communications if such correspondence includes a return email address. Because an email address is Personal Information, we protect the privacy of the sender by limiting access to these email messages. Only employees with a legitimate business need to access the emails are allowed to do so. For quality control purposes, email messages may be kept for a period of time. There may, however, be certain cases where hard copies may be kept on file, such as emails concerning product safety or consumer complaints. Information from email messages will not be used for marketing purposes and will be maintained in a secure location.
Our Website may make chat rooms, forums, message boards, and/or newsgroups (“Public Forums”) available to users. Please remember that any information disclosed in Public Forums becomes public information and you should exercise caution when deciding whether to disclose your Personal Information in these Public Forums. We do not permit children under thirteen (13) to participate in Public Forums unless they are monitored, the child’s parent or guardian has provided verifiable consent, or the Public Forum complies with the relevant legal requirements in another manner.
Collection of your Personal Data
We collect the following categories of Personal Data about you when you use or otherwise interact with our Products:
· Email address
· Company name
· Home/work/mobile telephone number
· Postal or other physical address
· Credit/debit card information
· Facebook profile information (when you use Facebook to log-in to our Products or to create an account for our Products)
· IP addresses and other information collected passively, as further detailed in the “Passive Collection” section below
· Device identifiers, as further described in the “Mobile Application” section below
· Your photos, when you upload them to our website or mobile apps
We collect and/or process your Personal Data in connection with the below activities related to our Products:
· Account registration
· Use of certain Product features
· Generating reports based on information collected from use of our Products
· Requesting service and support for our Products and providing such support
· Placing transactions or orders
· Registering to attend a seminar or webinar
· Participating in an online survey
· Billing and collecting payments for our Products
· Participating in discussion groups or forums
· Registering for newsletter subscriptions
· Customizing the advertising and content you see
· Requesting evaluation keys for our products
· Requesting ordering information of our products
· Generating personalized entertaintment images based on your uploaded photos
· Processing requests to our remote API
Processing of your Personal Data
· Personalizing, improving or operating our Products and business
· Better understanding your needs and interests
· Fulfilling requests you make related to the Products
· Providing you with information and offers from us or third parties
· Complying with our legal obligations, resolving disputes with users, enforcing our agreements
· Protecting, investigating and deterring against fraudulent, harmful, unauthorized or illegal activity
We process Personal Data for purposes such as:
· To process your orders and deliver the Products that you have ordered
· To provide reports based on information collected from use of our Products
· To keep you up to date on the latest Product announcements, software updates, software upgrades, system enhancements, special offers, and other information
· To explain how to better use our Products
· To provide support and assistance for our Products
· To provide the ability to create personal profile areas and view protected content
· To provide the ability to contact you and provide you with shipping and billing information
· To provide customer feedback and support
· To allow you to access the personalized entertainment pictures generated from your photos
· To allow you to process your pictures via our remote API
· To provide and administer opt-in contests, sweepstakes or other marketing or promotional activities on the Luxand.com or affiliate websites
· To the extent you choose to participate, to conduct questionnaires and surveys in order to provide better products and services to our customers and end users
· To support recruitment inquiries
· To personalize marketing communications and website content based on your preferences, such as in response to your request for specific information on products and services that may be of interest
· To contact individuals that you refer to us and identify you as the source of the referral
· To meet contract or legal obligations
You can choose whether to provide Personal Data to Luxand, but note that you may be unable to access certain options, offers, and services if they require Personal Data that you have not provided. You can sign-up, and therefore consent, to receive email or newsletter communications from us. If you would like to discontinue receiving these communications, you can update your preferences by using the “Unsubscribe” link found in such emails or by contacting us using the information in the “Contact Us” section of this policy.
Data Subject Rights
You have certain rights with respect to your Personal Data as set forth below. Please note that in some circumstances, we may not be able to fully comply with your requests, or we may ask you to provide us with additional information in connection with your request, which may be Personal Data, for example, if we need to verify your identity or the nature of your request. In such situations, however, we will still respond to let you know of our decision.
To make any of the following requests, contact us using the contact details referred to in the “Contact Us” section of this policy.
· Access: You can request more information about the Personal Data we hold about you. You can also request a copy of the Personal Data.
· Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging into your service account. Please contact us as soon as possible upon noticing any such inaccuracy or incompleteness.
· Objection: You can contact us to let us know that you object to the collection or use of your Personal Data for certain purposes.
· Erasure: You can request that we erase some or all of your Personal Data from our systems.
· Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
· Portability: You have the right to ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another entity where technically feasible.
· Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Products.
· Right to File Complaint: You have the right to lodge a complaint about Luxand’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.
How long we retain your Personal Data depends on the type of data and the purpose for which we process the data.
Luxand and our third party service providers automatically collect some information about you when you use our Products, using methods such as cookies and tracking technologies (further described below). Information automatically collected includes Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the website and/or Products.
In addition, when you use some of our Products, network information is transmitted back to us such as Product usage information. This information is transmitted back to us so we can determine how users are interacting with our Products, to assist us with improving our Products, and to correct any problems that may occur.
Cookies and Tracking Technologies
We partner with third parties to either display advertising on our website or to manage our advertising on other sites. Some of our third party partners use technologies such as cookies and other technologies to gather information about your activities on this website, our affiliates’ websites, and unaffiliated websites in order to provide you advertising based upon your browsing activities and interests.
When you download and use our Products, we automatically collect information on the type of device you use, operating system version, and the device identifier (or ”UDID“). We send you push notifications from time-to-time in order to update you about any events or promotions that we may be running. If you no longer wish to receive these types of communications, you can turn them off at the device level. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information.
We collect information about where you are located when you are using our Products. We use this information for purposes such as optimizing your connection to our data center and suggesting customizations to your experience with our Products (e.g. your language preference). We share this information with parties such as our data center provider and our advertising partners. If you do not wish to allow us to share your information in this manner please opt-out by contacting us at email@example.com.
We do not sell or rent your Personal Data to third parties for marketing purposes unless you have granted us permission to do so.
We share Personal Data within Luxand and its affiliated companies, and with third party service providers for purposes of data processing or storage.
We also share Personal Data with business partners, service vendors and/or authorized third-party agents or contractors in order to provide requested Products or transactions, including processing orders, processing credit card transactions, hosting websites, hosting event and seminar registration and providing customer support. We provide these third parties with Personal to complete/utilize the requested Product or transaction.
In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Data as set forth in this policy. As required by law, we may respond to subpoenas, court orders, or similar legal process by disclosing your Personal Data and other related information, if necessary. We also may use Personal Data and other related information to establish or exercise our legal rights or defend against legal claims.
We collect and possibly share Personal Data and any other additional information available to us in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Luxand's license agreement, or as otherwise required by law.
Transfer and Storage of Personal Data
Our Products may be hosted and operated in the United States (“U.S.”) through Luxand and its service providers. We may transfer your Personal Data to the United States (“U.S.”), to any Luxand affiliate worldwide, or to third parties acting on our behalf for the purposes of processing or storage. By using any of our Products or providing any Personal Data for any of the purposes stated above, you consent to the transfer and storage of your Personal Data, whether provided by you or obtained through a third party, to the U.S. as set forth herein, including the hosting of such Personal Data on U.S. servers.
D. NETWORK AND INFORMATION SECURITY
We will notify users of a data breach involving unencrypted Personal Information by email or by posting a notice on the affected Website. We also strive to limit access to Personal Information to employees performing a legitimate business function. We review our security procedures periodically to consider appropriate new technology and updated methods. Despite our efforts, no security measure is ever perfect or impenetrable.
It is your responsibility to keep your password confidential. Do not share this information with anyone. If you are sharing a computer with anyone you should always log out before leaving a site or service to protect access to your information from subsequent users.
E. USE AND DISCLOSURE OF INFORMATION
We are the sole owner of the information it gathers on the Website. We do not sell or rent Personal Information to third parties. We may share Personal Information with vendors who help us perform various internal functions necessary to operate our business. We may disclose Personal Information (a) in the good faith belief that we are required to do so by law; (b) if doing so is reasonably necessary to comply with legal process; (c) to respond to any claims; (d) to enforce the terms and conditions of our Websites; or (e) to protect the rights, property, or personal safety of our customers, or the public. We also may disclose your email address to our partners solely to send you email messages you have requested, or to ensure that you do not receive such messages if you have opted out of receiving them. Any vendors or partners with whom we may share Personal Information are permitted to obtain only the Personal Information they need to deliver the services requested. They are required to maintain the confidentiality of the information and are prohibited from using it for any other purpose. In addition, information about our customers, including Personal Information, may be disclosed as part of any merger, sale, transfer of company assets, or acquisition, if permitted by and done in accordance with applicable laws.
Our Website uses “cookie” technology. “Cookies” are short pieces of data generated by a web server that a website stores on a user’s computer. These files identify your computer and record your preferences and other data about your visit so that when you return to the Website, it knows who you are and can personalize your visit. Cookies may be linked to Personal Information about you. In addition, cookies are used to:
- measure usage of various pages on our Website to help us make our information more pertinent to your needs and easy for you to access;
- identify and categorized the internet webpages from which the visitor came to the Website and observe the browsing patterns; and
- provide functionality such as online orders, our services and other functionality that we believe would be of interest and value to you.
You may set your browser to block cookies (consult the instructions for your particular browser on how to do this), although doing so may adversely affect your ability to perform certain transactions, use certain functionality and access certain content on our Website.
We maintain log files, which contain Internet Protocol (“IP”) addresses. An IP address is a numeric address that is assigned to your computer by your Internet Service Provider. We do not link IP addresses to Personal Information, unless we notify you or unless necessary to enforce our Websites’ terms and conditions. In general, we use log files to monitor traffic on our Websites and to troubleshoot technical problems. In the event of abuse, however, we may block certain IP addresses.
Choices available to you
You can always choose whether or not to disclose personally identifiable information and that choice will not prevent you from using the Website. Please note, however, if you should choose to withhold requested information, we may not be able to provide you with some of the services dependent upon the collection of this information and you will be given an opportunity to “opt-in” and make your preference choices for any items that are optional and which are not prerequisite for our rendering such services.
You can choose at anytime to opt out of receiving emails from Luxand or from having your personally identifiable information shared with selected companies. If you want to opt out, you can do so by editing your preferences with respect to email or the sharing of information. If you elect to “opt out” we will not, as applicable, share your personal information with third parties or send you emails. However, we may continue to use your personal information for internal purposes, to enhance your user experience or as necessary to administer the site or comply with applicable law.
If you wish to opt out of receiving emails, the sharing or retention of any personal identification information, or otherwise change your personal preferences, you must contact us by email at: firstname.lastname@example.org.
To ensure that your request is honored, you must provide Luxand with information sufficient for us to accurately identify and access your records. The information we require is your full name, address and the email address you provided to Luxand when you requested services or products. We reserves the right to contact you to verify that we have accurately identified your record.
We do not collect Personal Information from visitors under the age of 13 (“children” or “child”) in connection with the registration on our Website. Nor do we collect any information from children in a manner inconsistent with the Children’s Online Privacy Protection Act (“COPPA”). COPPA provides parents with specific rights regarding their children’s privacy. For additional information and resources on COPPA, please visit the Federal Trade Commission Web site at http://www.ftc.gov/. The Luxand Web site and any products or services available on that site are not directed at children and, therefore, COPPA does not apply. However, we recognize that children may access this Web site and subscribe to the newsletter, purchase products and services, or download software programs. The collection of information is covered above. Parents and legal guardians may request from us to review, delete or stop the collection of the Personally Information of their child. You may do so by contacting us by email at: email@example.com.
For more on how we use information collected from users, including child users, please see our section “Collection and Use of Personal Information” above.
We protect our records in accordance with our obligations as defined by applicable Virginia statutes, including, but not limited to, the Virginia Privacy Protection Act of 1976, the Virginia Freedom of Information Act, and by any applicable U.S. federal laws. (See also Commonwealth of Virginia: Internet Web Page Privacy Statement Guidelines)
I. PRIVACY-RELATED INQUIRIES AND COMPLAINTS
Please note that if you provide us with inconsistent privacy preferences (for example, by indicating on one occasion that third parties may contact you with marketing offers and indicating on another occasion that they may not), we cannot guarantee that your most recent privacy preference will be honored.
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