Privacy Policy
Website Privacy Policy
Introduction
1.1 Important information and who we are
Welcome to Lovedoc Ltd’s Privacy and Data Protection Policy (“Privacy Policy”).
At Lovedoc Ltd (“we”, “us”, or “our”) we are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation (“GDPR”), the Data Protection Act 2018 and all other mandatory laws and regulations of the United Kingdom.
This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data.
The individuals from which we may gather and use data can include: Customers
Suppliers Business contacts
Employees/Staff Members
Third parties connected to your customers
and any other people that the organisation has a relationship with or may need to contact.
This Privacy Policy applies to all our employees and staff members and all Personal Data processed at any time by us.
1.2 Who is Your Data Controller
Lovedoc Ltd is your Data Controller and responsible for your Personal Data. We are not obliged by the UK GDPR to appoint a data protection officer, but have voluntarily appointed the following DPO:
Name: Pridatect, S.L.
Contact Email: legal@pridatect.com
Therefore, any inquiries about your data should either be sent to the above email. It can also be sent directly to the company, if you prefer, in a letter to 245 Woodcock Hill, Kenton, Harrow, HA3 0PG, United Kingdom.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
1.3 Processing Data on Behalf of a Controller and Processors’ responsibility to you
In discharging our responsibilities as a Data Controller we have employees who will deal with your data on our behalf (known as “Processors”). Therefore, the responsibilities described below may be assigned to an individual, or may be taken to apply to the organisation as a whole. The Data Controller and our Processors have the following responsibilities:
Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR (see 2.2 below for more information on those bases);
Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;
Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data;
Obtain the prior specific or general authorisation of the Controller before engaging another Processor;
Assist the Controller in the fulfilment of the Controller’s obligation to respond to requests for exercising the data subject’s rights;
Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller;
Maintain a record of all categories of processing activities carried out on behalf of a Controller;
Cooperate, on request, with the supervisory authority in the performance of its tasks;
Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller; and Notify the Controller without undue delay after becoming aware of a Personal Data Breach;
2 LEGAL BASIS FOR DATA COLLECTION
2.1 Types of Data / Privacy Policy Scope
“Personal Data” means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together below. Not all of the following types of data will necessarily be collected from you, but this is the full scope of data that we collect and when we collect it from you:
Profile/Identity Data: This is data relating to your first name, last name, gender, date of birth.
Contact Data: This is data relating to your phone number, addresses, email addresses, phone numbers.
Marketing and Communications Data: This is your preferences in receiving marketing information and other information from us.
Billing Data: This is information relating to your debit and credit card information such as the name attached to your payment details and your billing address.
Financial Data: These are your banking details e.g. your account number and sort code.
Transactional Data: This is information of details and records of all payments you have made for our services or products.
Technical Data: This is your IP address, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to engage with us.
Customer Support Data: This includes feedback and survey responses.
Usage Data: information about how you use our website, products, and services.
For the purposes of our business, we also collect what is known under the UK GDPR as special categories of Personal Data. We collect the following types of special Personal Data:
Political Data: Information about race, or ethnicity, religious beliefs, sexual orientation, and political opinions
Genetic information and biometric data
To collect this special kind of data we need enhanced legal justifications beyond the ordinary legal justifications under the UK GDPR. We explain which justifications we rely on in paragraph 2.2 (a) below.
2.2 The Legal Basis for Collecting That Data
There are several justifiable reasons under the UK GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:
“Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service.
“Contractual Obligations”: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.
“Legal Compliance”: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
“Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests – this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards.
For the special categories of data that we collect, the enhanced legal justification we rely on is:
(a) the data subject has given explicit consent to the processing of such Personal Data for one or more specified purposes (“Explicit Consent”)
3 HOW WE USE YOUR PERSONAL DATA
3.1 Sources of Data
We primarily obtain the data from you (including via the devices you use) while visiting the site. If we do not collect the personal data directly from you, we will also tell you the source of the personal data and, if applicable, whether it is sourced from publicly available sources.
3.2 Recipients, or Categories of Recipients, of the Personal Data
When processing your data, we work with service providers who have access to your data. Possible recipients of your personal data are: (i) software companies that enable us to provide our services, help us to improve them and/or serve us for marketing purposes (for example, to send newsletters, emails, manage customer contacts or applications); (ii) public bodies and administrations to the extent that we are legally obliged to do so; (iii) payment service providers; (iv) hosting providers; (v) social media platforms & (vi) service companies, such as tax advisors or lawyers.
For the purposes of fulfilling the contract, we may also disclose your personal data to anyone to whom we assign rights arising from the contractual relationship with you.
3.3 Marketing and Content Updates
You will receive marketing and new content communications from us if you have created an account and chosen to opt into receiving those communications. From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you.
3.4 Change of Purpose
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
3.5 Contact Form
The contact form on our website collects basic information relating to a query you may have regarding the website or App. We collect this data based on Legitimate Interest, and treat your data appropriately: once a query is complete, the data will be kept for a standard period of time prior to deletion. The only exception to this is when other legal obligations require us to keep the data for longer periods of time. You will be informed of these instances.
4 YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US
4.1 What Rights Do I Have Over Lovedoc Ltd’s Use Of My Personal Data?
As a data subject under the UK GDPR, you may have the right in law to:
● Information, in accordance with Art. 15 UK GDPR,
● Rectification, in accordance with Art. 16 UK GDPR,
● Data erasure (“right to be forgotten”), in accordance with Art. 17 UK GDPR,
● Limitation of processing, pursuant to Art. 18 UK GDPR,
● Data portability, according to Art. 20 UK GDPR and/or
● Objection to the processing, pursuant to Art. 21 UK GDPR.
To exercise these rights, you can send an email to us at any point at the following email address: charles.maddytrevitt@pridatect.com
We will handle any request to exercise these rights in accordance with the relevant laws, but please note that these rights may not be absolute. Lovedoc Ltd may refuse or deny a request in accordance with these rules, though where possible you will be informed why this is happening.
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.
We may also need to request specific information from you to help us confirm your identity and ensure you have the right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response
4.2 Information On The Right To Object Pursuant To Article 21 (4) UK GDPR
You have the right to object at any time, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) of the UK GDPR; this also applies to profiling based on these provisions. We will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the assertion, exercise, or defence of legal claims.
If your personal data is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling that is related to direct marketing.
4.3 What Control Do I Have Over My Account With Lovedoc?
You may delete your account at any time – this will remove your account page from our systems and our related software.
Your account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and by signing off after you have finished accessing your account.
You can access information associated with your account by logging into your account you created with us.
California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to charles.maddytrevitt@pridatect.com
Further information about app usage can be found on the App Privacy Policy. It is available through the App directly, and online here.
4.4 How Does Lovedoc Ltd Protect Customers’ Personal Data?
We are concerned with keeping your data secure and protecting it from inappropriate disclosure. Any Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. When we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession.
However, unfortunately no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of Lovedoc Ltd to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.
4.5 Opting Out Of Marketing Promotions
You can ask us to stop sending you marketing messages at any time by unsubscribing.
maWhere you opt out of receiving these marketing messages, we will continue to retain other Personal Data provided to us as a result of interactions with us not related to your marketing preferences.
5 YOUR DATA AND THIRD PARTIES
5.1 Will We Share Your Data With Third Parties?
We may share non-Personal Data with third parties. We may share your Personal Data with subcontractors when necessary and with your consent. The sub-contractors are also subject to our confidentiality obligations to use it only for the purposes for which we disclose it to them and pursuant to our instructions.
We may also share Personal Data with interested parties in the event that Lovedoc Ltd anticipates a change in control or the acquisition of all or part of our business or assets or with interested parties in connection with the licensing of our technology.
If Lovedoc Ltd is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or assign your Personal Data to a third party as part of or in connection with that transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern the further use of your Personal Data. In all other situations your data will still remain protected in accordance with this Privacy Policy (as amended from time to time).
We may share your Personal Data at any time if required for legal reasons or in order to enforce our terms or this Privacy Policy.
5.2 Third-Party Links
This Site may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy policy of every website you visit.
6 HOW LONG WILL WE RETAIN YOUR DATA FOR?
We store your personal data only as long as it is necessary to achieve the purpose of processing. In most normal cases, we store your data if you have consented to the processing until you revoke your consent. If we need the data to perform a contract, we retain the data for as long as the contractual relationship with you exists. If we use the data on the basis of a legitimate interest, we will retain your data for as long as your interest in deletion or anonymization does not prevail.
In addition, data may be stored beyond the outlined periods in certain rare circumstances where data must be kept in order to exercise legal rights or to comply with other legal obligations. In these cases, the data is deleted when a storage or retention period prescribed by law expires.
We store applicant documents for a period of six months if the application does not lead to an employment relationship and no further storage has been agreed.
7 AGE LIMIT FOR OUR USERS
You must not use Lovedoc Ltd unless you are aged 18 or older. If you are under 18 and you access Lovedoc Ltd by lying about your age, you must immediately stop using Lovedoc Ltd.
8 INTERNATIONAL DATA TRANSFERS
There is a transfer of data to third countries outside of the United Kingdom and European Union. Information we collect from you could be processed in the United States or other third countries. Some third countries, such as the United States, have not currently received an adequacy decision from the European Union under Article 45 of the GDPR which means that your data may not receive the same level of protection there as it does under the UK GDPR and European GDPR.
International data transfers are made based on contractual and other guaranteed safeguards provided for by law, which are intended to ensure adequate protection of your data and which you can view on request. We rely on the rules set out in Article 49 of the GDPR or, where applicable, on safeguards pursuant to Article 46 of the GDPR. We, and our processors, strive to apply appropriate measures to protect the privacy and security of your personal data. For this reason, we only process your personal data in accordance with the practices described in our Privacy Policy.
9 NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICY
We keep our Privacy Policy under review and will place any updates on this webpage. By using Lovedoc Ltd, you consent to the collection and use of data by us as set out in this Privacy Policy. Continued access or use of Lovedoc Ltd will constitute your express acceptance of any modifications to this Privacy Policy. If we are obliged to inform you of drastic changes, you will receive an email detailing these changes.
Date: 28th September 2022.
