Privacy and Cookie Policy

Last updated: July 2021
INTRODUCTION

Who are we?

We are Levellr Ltd, a company incorporated and registered in England and Wales with address 4 Upper Cheyne Row, London SW3 5JN and company number 12909887. Where we decide the means or purpose of processing your personal data, we are the data "controller."

What’s this policy about?

This policy explains how we process your personal data as a data controller. We update this policy from time to time so please check back in.

The policy applies to your use of our website levellr.com including purchases through that website (together the “Services”).

Please note that other websites/services not mentioned here are not operated by us, and you should refer to the privacy policies on those sites to understand how your data is used.

How do you contact us?(if you have questions about this policy or to exercise your rights)

Write to us: info@levellr.com.

If we can’t resolve your issue, you can also get in touch with the Information Commissioner’s Office in the UK at: https://ico.org.uk/concerns.

(or if you live outside the UK in a European country, you can submit a complaint to the supervisory authority in your country).

What are your rights?

You have the following rights, although these rights may be limited in some circumstances:

  • Ask us to send a copy of data to you or someone else
  • Ask us to restrict, stop processing, or delete your data
  • Object to our processing of your data
  • Object to use of your personal data for direct marketing
  • Ask us to correct inaccuracies

If we rely on consent to process data, or send direct marketing, you can withdraw consent by contacting us via the email address above.


YOUR PERSONAL DATA AND HOW WE USE IT

Your data

How we use it

Sources and recipients

Enquiry data(information we receive when you get in touch with questions or instructions) including:

  • Name
  • Contact details
  • Other personal data you send to us as part of enquiries or instructions.

How long we keep it

6 years from when our relationship with you ends.

We process this information to respond to your enquiries, for example by email or via our live chat support.

Legal basis

We process this information in accordance with the terms of our contract with you (where we need this information to provide our Services to you) or to take steps at your request prior to entering into a contract.

We also use this to pursue our legitimate interests in responding to enquiries, and in order to understand our customers and improve our Services.

More information

You may be required to provide us with certain information in order for us to respond to your enquiries.

Sources

  • We collect this information from you

Recipients

  • We may share aspects of your queries with Partners (i.e. third-party high-profile individuals or entities who typically host communities on levellr.com) where necessary for us to action your enquiry.
  • We do not currently have any chat support functionality on levellr.com.

Platform/Customer data

(information we receive when you register for, or use, our web-based platform or when we obtain feedback from you) including:

  • Name
  • Gender, date of birth
  • Contact details
  • Usernames (e.g. your Telegram ID)
  • Billing data (billing name/address)
  • Your order and transaction history
  • Communications through our Services or the communities to which you are granted access
  • Your feedback and survey responses

How long we keep it

6 years from when our relationship with you ends.

We process this information to provide our Services.

Legal basis

We process this information in accordance with the terms of our contract with you in order to enable you to login to and use our web-based platform and access our Services.

We also use this to pursue our legitimate interests in obtaining feedback and survey responses from you to understand market trends, our customers, how they use our Services, and to improve our Services, and to monitor compliance with our terms of service.

More information

You may be required to provide us with certain information in order for us to provide our Services.

Sources

  • We collect this information from you. If someone is purchasing something for you through our platform, for example an experience as a gift, we may collect this from the purchaser. If you provide any information relating to a third party when using the Service, please ensure that you share a copy of this privacy notice with them and that they are happy for their details to be shared.

Recipients

  • We may process this information using Shopify (based in Europe, the USA and Canada) who operate our e-commerce platform or Stripe, Boldor InviteMember(which may access your data from its international locations including the USA), our payment processors.
  • Where necessary for us to provide our Services we may share certain information (such as details of your orders) with relevant Partners.
  • Where necessary for us to provide our Services (e.g. where we need to grant you access to a Telegram community) we may share the access levels to be granted for your username with the relevant third party platform.

Mailing lists(information we receive when you provide your email information) including:

  • Name
  • Email address or Telegram username
  • (if relevant) Details of which email list you have signed-up to

How long we keep it

Until you indicate that you no longer wish to receive our marketing emails.

Where we have your consent or you have opted-in, we will send you emails or Telegram messages with news about our company and services.

Legal Basis

  • Consent; or
  • “Soft opt-in” or B2B: In some instances (such as with existing customers, or if you are a corporate subscriber) the law may permit us to process your personal data to send you marketing by email or Telegram direct message that we think is of interest on the basis of our legitimate interests, being our legitimate interest to promote our business.

More information

If you would like to be removed from marketing lists please let us know by clicking unsubscribe at the bottom of any marketing email you receive or by replying “STOP” on Telegram.

Sources

We collect this data from you if you decide to sign-up.

Recipients

We use Klaviyo to help manage our email lists and Telegram to send marketing messages.

Analytics
(information about how users interact with our Services which might be associated with a unique identifier) including:

  • browser type and version, IP address, approximate location and time zone, access logs, device type and settings, operating system, and other information provided by browser or device;
  • use you make of our Services, including the content you visit, links you click, terms you search for, websites you have come from, how long you spend on our Service and how you interact with it.

How long we keep it

After 26 months underlying data is deleted, but we may retain some anonymous, aggregated statistics generated from that data.

Where we have your consent, we use a third party service (Google Analytics, InviteMember and Shopify) to collect information about visitors to our website and users of our platform, to understand how many people visit, where they come from, and how they interact with our Services, and to help us improve and maintain our Services and address bugs.

Legal basis

To the extent that our analytics involve storing or accessing information on your device other than as strictly necessary for us to provide our Service to you, we obtain your prior consent.

Otherwise, we process this information, to the extent it is personal data, on the basis of our legitimate interest to understand how you use our Services, and to improve those Services.

More information

You can find out more about how Google uses data by clicking here and how Shopify uses cookies for analytics by clicking here .

You can withdraw your consent at any time by contacting us, or in the case of Google analytics, opting-out using the following link: Google Analytics.

Sources

We use Shopify, InviteMember and Google’s services to collect this data from you when you visit our Services.

Recipients

Google in the USA, InviteMember in the USA and Shopify in the USA and Canada, collect and process analytics information on our behalf.

Where explicit retention periods are not described above, we hold data for as long as necessary bearing in mind the purpose for which it was collected. At the end of the retention period, we assess whether it is necessary to continue to retain information to achieve the purposes for which it was collected. To determine appropriate retention periods, we consider the amount, nature, and sensitivity of the data, the potential risk of unauthorised access, and legal requirements.


COOKIES, ANALYTICS AND SIMILAR TECHNOLOGIES

Cookies, pixels and other technologies store and access data on your device to help websites and apps work. This table explains their purpose, how long they last, and who else can access their data. We get your consent to use them unless they’re essential for our sites, apps or services.

Most browsers allow control over cookies, for more information: Google Chrome | Microsoft Edge | Mozilla Firefox | Microsoft Internet Explorer | Opera | Apple Safari.

Cookie/data

Duration

Purpose

Access

_ga

_gat

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Up to 24 months

To collect information about how people interact with our Services & generate reports to help us identify problems, understand how people use our Services, and improve them.

We use Google Analytics to set these cookies.

You can find out more about how Google uses data by clicking here.

You can opt-out here: Google Analytics.


STORAGE, TRANSFERS AND DISCLOSURE

Storage & Transfers

Save where indicated otherwise, your personal data is securely stored in the UK. Where we use data processors outside the UK and European Economic Area, and transfer personal data to a country which does not provide an adequate level of protection, we use contracts or other safeguards which give personal data the same or equivalent protection it has in Europe or the UK. For more information drop us a line using the contact details at the start of this policy.

Disclosure

We may disclose your personal data:

  • Where required by law, government, competent authorities or the courts or to establish, exercise or defend our legal rights, and for the purposes of preventing crime and fraud (for example, we may share personal data with our professional advisors, investigators, or credit reference agencies).
  • With members of our corporate group, insurers, advisers, suppliers and subcontractors, as necessary for the purposes set out in this policy.
  • With our service providers and subcontractors, provided that they only use that personal data on our instructions and not for their own independent purposes.
  • If involved in an investment, merger, acquisition, or sale of our organisation or assets, personal data we hold may be shared on the basis of the legitimate interests of us, our shareholders, customers and other parties to a transaction, unless those interests are outweighed by prejudicial impacts upon you.