This Privacy and Cookies Policy explains how information about you is collected, used, and disclosed by Lifelabs.io Limited ("we" or "us"). This Privacy and Cookies Policy applies to information we collect when you use our website at https://www.lifelabs.io/ and other online products and services that link to this Privacy and Cookies Policy, including our bounty programme and other subscription services (collectively, the "Services"). Please read this Privacy and Cookies Policy carefully. By accessing or browsing our website, or using any of our Services, you confirm that you have read and understood this Privacy and Cookies Policy in its entirety.
We may change this Privacy and Cookies Policy from time to time. If we make changes, we will revise the date at the bottom of this Privacy and Cookies Policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you a notification). We encourage you to review the Privacy and Cookies Policy whenever you access our website or the Services or otherwise interact with us to stay informed about our information practices and the ways you can help protect your privacy.
We are Lifelabs.io Limited, a company registered in England and Wales with registration number 10798976, whose registered office is at Henwood House, Henwood, Ashford, Kent, England, TN24 8DH and we are the data controller of any personal information that we collect from you.
We respect your right to privacy and will only process personal information you provide to us in accordance with applicable data protection laws.
We do not and will not knowingly collect information from any unsupervised child under the age of 13. If you are under the age of 13, you may not use our website unless your parent or guardian has provided us with their consent for your use of this Website.
We collect information you provide directly to us. For example, we collect information when you create an account, participate in any interactive feature of the Services, fill out a form, participate in a community or forum discussion, complete an exchange transaction, apply for a job, request customer support or otherwise communicate with us. The types of information we will collect include your name, social security or national insurance number or other government ID number, date of birth, email address, postal address, phone number, certain virtual currency information, and any other information you choose to provide.
Precisely what information we collect from you will vary depending on which of our Services you are using or subscribing for and the extent to which you permit our Services to interact with your social media account(s). See below for more detail.
When you access or use our website or Services, we automatically collect the following information about you:
Log Information: We log information about your use of our website or the Services, including the type of browser you use, access times, pages viewed, your IP address, your country of origin, length of time on the site and the page you visited before navigating to our website or Services.
Device Information: We collect information about the computer or mobile device you use to access our website or Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
We and our service providers (for example our web hosting provider) may from time to time use various technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that could be used (for example) to help us improve our website and Services and your experience, see which areas and features of our website and Services are popular and count visits, manage the registration process for accounts, remember your site preferences, retain certain information to process orders for exchange transactions and retain information to provide you with support. Web beacons are electronic images that may be used in our website and Services or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness.
Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that choosing to remove or reject cookies could affect the availability and functionality of our website and/or Services.
We do not currently use any cookies for the operation of our website or any of the Services but will let you know if that changes by updating this Privacy and Cookies Policy.
We will also obtain information from other sources and combine that with information we collect through our website or Services. For example, we will collect information about you from social media platforms (including Facebook, Instagram and Twitter) if you have "followed" or "liked" us on the relevant platform.
We need to have a legal basis or bases for using your personal information for the purposes set out in this Privacy and Cookies Policy. We consider that our legal bases are as follows:
our use of your personal information is necessary for the performance of the website in accordance with our website terms and conditions and our Services in accordance with the applicable terms and conditions; or
you have consented to our use of your personal information (in the case of marketing activity); or
use of your personal information is necessary for the purposes of our legitimate interests or the legitimate interests of a third party. These legitimate interests are to:
run, grow and develop our business (as well as the businesses of our group companies);
ensure compliance with best industry practice with respect to "know your client" (KYC) and anti-money laundering (AML);
operate our website;
carry out marketing, market research and business development;
place, track and ensure fulfilment of orders with our suppliers; and
for internal group administrative purposes.;
If we rely on our (or another person's) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other person's) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information. You can ask us for information on this balancing test by using the contact details at paragraph 13 below.
If we have asked for your consent to collect and use certain types of personal information, you may withdraw your consent at any time by contacting firstname.lastname@example.org.
We use information about you for the following purposes:
Provide, maintain, and improve our website and Services;
Provide and deliver the Services you request, process transactions, and send you related information, including confirmations and invoices;
Send you technical notices, updates, security alerts, and support and administrative messages;
Send you promotional offers and other marketing material via social media platforms (if you have "liked" or "followed" us on the relevant platforms);
Respond to your comments, questions and requests, and provide customer service;
Resolve disputes and troubleshoot problems;
Monitor and analyse trends, usage, and activities in connection with our website and Services;
Conduct anti-money laundering and “know your customer” checks in compliance with best practice;
Link or combine with information we get from others to help understand your needs and provide you with better service; and
Carry out any other purpose for which the information was collected, as set out in this Privacy and Cookies Policy or otherwise communicated to you.
We will only retain information (including personal information) about individuals for as long as is necessary in the circumstances. For example:
for so long as you hold an account with us, we will retain the personal information that is necessary for us to administer that account and will delete it within two (2) years of that account ceasing to be active;
if your LIFEwallet becomes dormant, we will keep hold of the necessary personal information so that you are able to access your wallet but may contact you to check whether you still require the wallet (and therefore require us to continue to hold your personal information). If we do not hear from you we will delete your personal information within five (5) years of your LIFEwallet becoming dormant. If we do hear from you we will contact you again if the LIFEwallet remains dormant; and
where an individual registered an interest in a new product, we will retain that individual's contact details so that we can tell them when it is released and keep them updated about the product. Due to the time it takes to develop products it may be up to two (2) years after the point at which that individual first registered their interest before the product is released. Individual’s information will be deleted within two (2) years of any of either: (1) the product being released and the individual not engaging with it further or (2) the product development being discontinued.
We will delete all personal information when we no longer need it except where we need to keep any personal information to comply with our legal obligations, resolve disputes, comply with industry best practice with respect to KYC or AML or enforce our agreements.
We will transfer personal information that we collect from you to third party data processors located in countries that are outside of the European Economic Area ("EEA") (including to the United States of America) in connection with the above purposes. Please be aware that countries which are outside the European Economic Area may not offer the same level of data protection as the United Kingdom, although our collection, storage and use of your personal data will continue to be governed by this Privacy and Cookies Policy. We will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this Privacy and Cookies Policy. These measures include the following, as permitted in Articles 45 and 46 of the General Data Protection Regulation:
in the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield (see further https://www.privacyshield.gov/welcome); or
in the case of entities based in other countries outside the EEA, entering into European Commission approved standard contractual arrangements with them.
We will share information about you as follows or as otherwise described in this Privacy and Cookies Policy
With vendors and other service providers (including Amazon and Microsoft) who need access to such information to carry out work on our behalf;
In response to a request for information if we believe disclosure is in accordance with any applicable law, regulation or legal process, or as otherwise required by any applicable law, rule or regulation;
If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of LIFElabs or others;
In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
With your consent or at your direction; and
With group companies on occasion for specific marketing campaigns or promotions and third party contractors and suppliers in connection with that work.
We will also share aggregated or de-identified information, which cannot reasonably be used to identify you.
You have the following rights in relation to your personal information:
the right to access to any personal information we hold about you. You have the right to ask us to provide you with copies of personal information that we hold about you at any time, subject to a fee specified by law; confirmation as to whether your personal information is being used by us; details about how and why it is being used; and details of the safeguards which are in place when we transfer your information outside the EEA;
the right to ask us to update or correct any out-of-date or incorrect personal information that we hold about you (in accordance with applicable data protection laws);
the right to ask us to restrict the way that we process your personal information in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us using the details in paragraph 13;
the right to ask us to provide your personal information to a third party provider of services (where we use your personal information on the basis of your consent or for the performance of a contract);
the right to ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our, or another person's, legitimate interest.; and
the right to opt out of any marketing communications that we (or any third party to whom we have disclosed your personal information with your consent) may send you.
If you wish to exercise any of the above rights, please contact us by email at email@example.com.
If you want us to stop using or to delete your personal information, you can contact us and tell us why. In certain circumstances we may not be able to stop using your personal information but, if that is the case, we'll let you know and tell you why.
While no online or electronic system is guaranteed to be secure, we take reasonable measures to help protect information about you from loss, theft, misuse, and unauthorized access, disclosure, alteration and destruction.
If you have any questions about this Privacy and Cookies Policy, please contact us by email at firstname.lastname@example.org.
This policy was last amended in May 2018.