PRIVACY POLICY
INTRODUCTION
LTV Mobile, Inc. (“LTV Mobile” or “we” or “us” or “our”) cares about our users’ privacy and is committed to disclosing our data practices. We’ve always placed the highest value on transparency, quality, and privacy.
The purpose of this privacy policy is to set forth our current privacy practices with regard to the information we collect when you interacts with our site (“LTV Mobile Website” or “Website”), use our services (“Services”), use our contact and registration forms or when you receive our newsletter. LTV Mobile processes personal data in accordance with applicable laws and especially all the data protection laws and the General Data Protection Regulation (EU) 2016/679 (“GDPR”).
For information on how we treat information collected from and about you when you interact with a mobile application or website that displays LTV Mobile advertisements, please visit the LTV Mobile End-User Privacy Policy.
If you access and use this Website or our Services you accept this Privacy Policy. If you don’t concur with the provisions of this Privacy Policy you should not use the Website.
COLLECTION OF INFORMATION
LTV Mobile may collect information provided when you use our Website, our Services, our contact and registration forms or when you receive our newsletter. Additionally, we may use cookies and web beacons to monitor traffic patterns and collect information about previous visits to our web site, as described in paragraph 6.
When we say “Personal Information,” we mean individually identifiable information (hereinafter also “PII”) that would allow us to determine the actual identity of and/or directly contact a specific living person (as defined in article 4.1 of GDPR.), such as an email address or telephone number.
We collect PII when it is provided to us, e.g. through our page “Contact us” in order to request information, so when we are contacted directly by an individual through the LTV Mobile Website and the individual voluntarily provides personal information to us, such as by submitting a question or registering to use one of the main LTV Mobile Services. The PII we collect may include: name, address, phone number, email address, Company address or phone number, Tax identification number Payment and invoice details or any other information provided to us.
CHILDREN: We do not knowingly or intentionally collect any PII about children under the age of 13. If you believe that information about your child under the age of 13 may have been provided to LTV Mobile and/or collected by us, please contact us at privacy@LTV Mobile.com.
LTV Mobile may use non-personal aggregated information, including such that was derived from PII but anonymized or pseudonymized to remove its personally identifying characteristics, including for statistical purposes. LTV Mobile will not sell, trade or rent PII, excluding aggregated data, to any third party unless we have your prior consent.
PURPOSES OF COLLECTION
When you provide PII directly to us via the Website or email, it is used solely for the purposes identified at the point at which you provide the information (e.g. for general marketing purposes or to notify you regarding updates to our Services or responding to general inquiries or customer support requests). Your local law may require to set out the legal basis on which we rely in order to process your personal data. Below you will find an outline of the purposes for which we may process your PII and the indication of a relevant legal basis for such processing pursuant to GDPR:1. registering your account and verifying your identity in order to enter into a contract with you (article 6.1. point b) of GDPR);
2. performing our Services, managing your account, processing transactions/issuing invoices, managing customer support etc. (article 6.1. point b) of GDPR);
3. pursuing claims, defending against claims, responding to your requests, preventing and responding to actual or potential fraud, intellectual property or infringement of illegal activities; monitoring compliance with our contractual documentation, storing data for archiving, etc. (article 6.1. point f) of GDPR, our legitimate interest to process the data in these cases);
4. conducting necessary tax and accounting operations (article 6.1 point c) of GDPR, according to our legal obligations to conduct relevant tax and accounting operations);
5. performing marketing of our Services, as our legitimate interest (article 6.1. point f) of GDPR) to promote our products and Services. Sometimes we also ask you for your voluntary consent to the specific form of marketing, i.e. sending commercial information via e-mail (newsletter) or contacting with you by phone for our commercial purposes;
6. When you give us your voluntary consent, we process your PII by using Cookie technology in scope and for the purposes described in our Cookies Paragraph 6.
IMPROPER USE OF THE WEBSITE
You undertake NOT to use the Website contents to: a) engage in unlawful or illegal activities or activities in bad faith and contravening public order; b) disseminate content or propaganda of a racist, xenophobic, pornographic-illegal nature, advocating terrorism or attacking human rights; c) try to access and, where appropriate, use the email accounts of other users and modify or manipulate their messages. You undertake NOT to use any of the content of the Website for illegal purposes, harmful to the rights and interests of third parties.
You are required and undertake not to transmit, disseminate or make available to third parties any kind of material contained on the Website, such as information, texts, data, content, messages, graphics, drawings, sound and / or image files, photographs, recordings, software, logos, brands, icons, technology, photographs, software, links, graphic design and source codes, or any other material to which you has had access, without this list being exhaustive.
HOW WE SHARE INFORMATION
LTV Mobile will not share your PII with other companies, except under the following limited circumstances:
Compelled Disclosures:
On rare occasions, we may share your personal information when compelled to do so by government authorities or as otherwise required or permitted by applicable laws and regulations (e.g., pursuant to law enforcement inquiries, subpoenas or court orders). LTV Mobile may also share your personal information with third parties if we believe in good faith that disclosure is appropriate to protect our rights, property or safety (including the enforcement of the LTV Mobile Terms of Use, or to protect the rights, property or safety of third parties.
Service Providers:
To trusted services providers who work on our behalf, who do not have an independent use of the information we disclose to them, and who have agreed to adhere to the rules set forth in the privacy statement.
Business Transfers:
In the event that LTV Mobile is (or substantially all of its assets are) acquired by a third party pursuant to an acquisition, merger, sale, reorganization, liquidation or similar business transfer, the personal information stored in our databases may be one of the transferred assets.
Non-Personal Information:
LTV Mobile may share aggregate or anonymous information with Business Partners and other third parties in accordance with the terms of this Policy.
COOKIES
When you interact with the LTV Mobile Website or our Services, we may also automatically collect information from your activities through the usage of Cookies, Log Data and similar technologies on our Website. A cookie is a text-only string of information that is stored locally in the cache of your computer's Internet browser. Cookies enable the recognition of the Internet browser upon your next visit to our website, making our offer more user-friendly and more effective. These small text files can tell companies what you are doing online, even though they usually don't record your name or other personally identifiable information. They are used all over the Web. LTV Mobile may place cookies on your computer and/or mobile device, in addition to any placed by advertisers.
We use those technologies in order to personalize our Website to provide you with customized content and to act within our advertising purposes. We may also use this information for analytics and monitoring purposes regarding the effectiveness of our performance, including the collection of the aggregate Website usage data.
The data mentioned above may include:
1. information about your interactions with the Site;
2. technical information about your computer (URL information, cookie data, your IP address, device ID, device attributes, the types of devices you are using to access our Site and/or use the Services, network connection type, browser type, internet service provider, etc.;
3. demographic information (gender and preferences by using Log Files, ZIP code, age).
For the Website we usually use:
Session Cookies
These are temporary cookies that expire at the end of a browser session; that is, when you leave the site. Session cookies allow LTV Mobile to recognise you as you navigate between pages during a single browser session and allow you to use the Website most efficiently. These cookies help us maintain security and verify your details whilst you use the Website as you navigate from page to page, which enables you to avoid having to re-enter your details each time you enter a new page.
In addition to cookies which send information to us, we also use cookies which collect information and send it to third parties too:
Google Analytics cookies.
Google Analytics is a web analysis service provided by Google Inc. (“Google”). We use this service to acquire data and reports about how visitors are using the website. Google can provide this information to third parties in case Google is legally obligated to do so, or if third parties process the information on behalf of Google. We can in no way influence these actions. Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services. Google may use the data collected to contextualize and personalize the ads of its own advertising network.
Personal Data collected: Cookie and Usage Data. Place of processing : USA – Privacy Policy – Opt Out.Google Conversion Tracking cookies.
Google AdWords conversion tracking is an analytics service provided by Google, Inc. that connects data from the Google AdWords advertising network with actions performed on this Website. The conversion tracking cookie is set when a user clicks on an ad delivered by Google. These cookies will expire after 30 days and do not yield personal identification.
Personal Data collected: Cookie and Usage Data.
Place of processing: USA – Privacy Policy.
Only for the re-engagement activity we use:
Adroll Retargeting cookies.
AdRoll is an advertising service provided by Semantic Sugar, Inc that allow this Website and its partners to inform, optimize and serve advertising based on past use of this Website by the user. This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity. Personal Data collected: Cookie and Usage Data. Place of processing : USA – Privacy Policy.
CHOICE/OPT-OUT
You can manage cookies by using features and functions available on most Internet browsers. For example, most browsers will allow you to choose what cookies can be placed on your computer and to delete or disable cookies. You can find instructions for managing cookie controls on websites for particular browsers. For example:
You may also refuse/revoke your consent to third-party cookies by accessing to links of third parties listed above or visiting the website http://www.youronlinechoices.com/.
DATA RETENTION POLICY
The PII provided will be kept by LTV Mobile until its deletion is requested by the interested party, unless otherwise specified. For example, we store Information about you when you have an account for our Services and when you use them, even if you delete your account, until you request its deletion. If we use the PII on the basis of a legitimate interest, we keep them until you oblige us to delete or anonymise them.
SECURITY
The security of your information is important to us, including but not limited to the PII collected via the website. LTV Mobile has implemented reasonable security measures to protect the information, both during transmission and once it is received. This includes but is not limited to the use of firewalls and encryption. No method of transmission over the Internet or method of electronic storage is 100% secure; therefore, while the company strives to use commercially acceptable means to protect your information, it cannot guarantee absolute security. If you have any questions about these security practices, please email info@LTV Mobile.com.
DATA TRANSFER TO THIRD COUNTRIES
In order to process and store the data we collect, this Data is sometimes transferred to countries outside the European Economic Area (EEA). Regarding to this treatment the European Commission has adopted an adequacy decision (Privacy Shield), in order to protect storage and processing of data.
You may also learn more about:
https://www.privacyshield.gov/Program-Overview
https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32010D0087
https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en
INFORMATION COLLECTED BY OTHERS
Please be advised that we do not control and are not responsible for the privacy practices of any third party, including, but not limited to, LTV Mobile customers, and any website or service that links to or from our website or the LTV Mobile Services. We require LTV Mobile customers to maintain a privacy policy that fully and accurately discloses their data collection practices, but we cannot control the actions of LTV Mobile customers, so please be sure to review the privacy policies of any websites and applications that you may use. This site may contain links to other sites. LTV Mobile is not responsible for the privacy practices or content of these other sites. When you leave our site or view a portion of a third party’s site through our site, we encourage you to read the privacy policies of each such site. This Privacy Policy applies solely to information collected by LTV Mobile.
YOUR RIGHTS
You have the right to access, rectify, right to object, claim, block about your data, as better detailed below:
If you want exercise the aforementioned rights, please contact our Data Protection Officer (as defined in article 37 – 39 of GDPR, appointed by LTV Mobile to watch the security of your PII) at privacy@ltvmobile.com.
CHANGES TO PRIVACY POLICY
When we make a material change to this Privacy Policy, we will inform you by posting a notice on the homepage of this site that the policy has been updated and by changing the date on this page noting when the policy was last updated.
CONTACT LTV Mobile
If you have any questions or concerns regarding this Privacy Policy, please email us at privacy@LTV Mobile.com, contacting our Data Protection Officer.
We will make every effort to resolve your concerns.