Zasady ochrony prywatności
Effective date: September 18, 2020
Last modified: September 18, 2020
LIVEXP LEARNING LTD is the publisher and operator (referred to as the “Company”, “we”, “our” or “us”) of the LIVEXP website and application (referred to as the “LiveXP”).
The Company is committed to protecting your privacy and handling your personal data in an open and transparent manner. The personal data that we collect and process will vary depending on how you use LiveXP.
- provides an overview of how the Company collects and processes your personal data and tells you about your rights under the EU General Data Protection Regulation (“GDPR”);
- is directed to natural persons.
- when we refer to “personal data” or “personal information” we mean data which identifies or may identify you and which may include, for instance, your email or IP address;
- when we refer to “processing” we mean the handling of your personal data by us, including collecting, protecting and storing your personal data; and
- when we refer to “sensitive data” we mean personal data which may reveal information about racial or ethnic origin, political opinions, religious beliefs, trade union activities, physical or mental health, sexual life, genetic or biometric data.
1. Who we are
LIVEXP LEARNING LTD limited liability company, registered in the Republic of Cyprus under registration number HE 408450, having its registered office at 12 Chrysanthou Mylona, Harmonia Building, Block 1, 1st Floor, Flat 15, 3030 Limassol, CYPRUS.
2. How we collect your personal data
We obtain your personal data mainly through any information you provide directly to us through LiveXP. Sometimes your personal data can also be shared with us, if for example you use an authentication system to Log in. Below is a list of ways we collect your personal data:
- when you visit and/or use LiveXP;
- when you complete our registration form;
- when you log in to LiveXP using an authentication system;
- when you post materials or upload content;
- when you participate in chat sessions;
- when you take part in surveys or report a problem with LiveXP; and/or
- when you contact with us via email or other ways of communication.
It does not apply to information collected by:
- us offline or through any other means, including on any other website/application operated by us or any third party (including our affiliates and subsidiaries); or
- any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the LiveXP. 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.
3. If you fail to provide personal data
Where we need to collect and process your personal data in order to provide you with our services and you fail to provide that data when requested, we may not be able to provide you with access to LiveXP and/or the services we offer. In this case, we may have to suspend your access to the LiveXP or, if you are a User, prohibit any access to non-public areas of the LiveXP or restrict the operation of your account and the services we provide to you.
4. Personal data that we collect and process
Personal data we collect and process from Browsers
- Technical Data, including your Internet Protocol (IP) address and associated country, your browser type and version, time zone setting and location, smart device information, mobile phone network information, operating system and platform and other technology on the devices you use to access LiveXP;
- Cookies including web beacons. For more information on the cookies we collect, please visit out Cookies Policy;
- User Submitted Data, including data collected for a specific function, for instance a contest or a survey;
- Communications and correspondence, including any correspondence between you and us and any other communication between you and anyone else on the LiveXP, including customer service requests, emails and live chats;
- Consents, including any permissions, consents or preferences that you give to the LiveXP.
Personal data we collect and process from Users
- All personal data we collect from Browsers, set out in paragraph 4(a) above;
- Contact Data, including username or similar identifier, password, full name and email address. We may also collect your photo or video, if such is uploaded to your profile;
- Usage Data, including data about which products you use and purchase, all orders you place on the LiveXP and all metrics and measurements regarding your orders, and any other of your activities on the LiveXP;
- User Submitted Data, including data collected at your discretion for a specific function, for instance your username and password, your interests, preferences, feedback and survey responses, or any text, images, forum comments or other content or media you choose to upload on the LiveXP;
- Transactional Information, including fund transfers and other details of products and services you have purchased or received from us; and
- Marketing Data, including preferences in receiving marketing from us, our affiliates and third-parties.
5. Sensitive data
Currently we do not process sensitive data.
6. Automated personal data collection
As you navigate through and interact with LiveXP, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect these data by using cookies and other similar technologies. We may also use these technologies to collect information about your online activities across third-party websites. Please see our Cookies Policy for further details.
7. Why we need your personal data and how we use it
We will most commonly use your personal data in the following circumstances:
- where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
- where we need to comply with a legal or regulatory obligation; and/or
- where you have given us your consent.
Below, we describe these circumstances in further detail.
Performance of our services to you
Provision of services
We may collect and process your personal data where it is necessary in order to present LiveXP and its contents to you, including any interactive features on LiveXP and to provide you with information, products or services that you request from us.
Please note that if you do not agree to provide us with the requested information, it may not be possible for us to continue to operate your account and/or provide you with the services we provide to our Users.
Customer management (Users Only)
We may collect and process your personal data where it is necessary in order to manage a User’s account, to provide customer support and notices to Users about their account, and inform you about any notices about changes to the website/application or any products or services we offer or provide through it.
Customization of content (Users Only)
We may collect and process your personal data where it is necessary in order to perform research and analysis about your use or, or interest in, LiveXP content and/or services, so as to develop and display content and advertising tailored to your interests on LiveXP.
We may collect and process your personal data where it is necessary in order to determine whether users of the LiveXP are unique, or whether the same user is using the LiveXP on multiple occasions, and to monitor aggregate metrics such as total number of visitors, pages viewed and demographic patterns.
Functionality and security
We may collect and process your personal data where it is necessary to diagnose or fix technology problems, and to detect, prevent, and respond to actual or potential fraud, illegal activities, or intellectual property infringement.
Other legitimate interests
In addition to the above, we may process your data, to the extent required for our business needs in order to:
- develop new services on LiveXP as well as analyze and target new markets;
- protect our legal rights and interests (including legal claims and preparing our defense in litigation);
- monitor, maintain and improve internal business processes, information and data, technology and communication solutions and services;
- ensure network information security, including monitoring Browsers’ and Members’ access to our information technology for the purpose of preventing cyber-attacks, unauthorized use of LiveXP and prevention or detection of crime;
- send you relevant marketing information (including details of other services provided by us which we believe may be of interest to you), but only where you are a User of the LiveXP (For more information, see “Choices About How We Collect, Use and Disclose Your Personal Information”);
- monitor the performance and effectiveness of our services and the LiveXP; and
- assess the quality of our customer services.
For compliance with legal obligations
When you visit and/or use and/or register in LiveXP (and throughout your relationship with us), we are required to comply with certain legal and regulatory obligations which may involve the processing of your personal data. This may include processing to:
- perform checks and comply with laws relating to fraud;
- manage contentious regulatory matters, investigations and litigation.
You have provided your consent
We will ask for your consent when we wish to provide marketing information to you in relation to our services which we believe may be of interest and of benefit to you, but only where you are a User.
You have the right to revoke your consent at any time. However, any processing of personal data prior to the receipt of your revocation will not be affected.
8. Who we share your personal data with
- to our authorized service providers that perform certain services on our behalf, such as Stripe. These services may include fulfilling orders, processing credit card payments, risk and fraud detection and mitigation, providing customer service, performing business and sales analysis, customization of content, analytics, security, supporting LiveXP functionality, and supporting contests, surveys and other features offered through LiveXP. These service providers may have access to personal data needed to perform their functions but are not permitted to share or use such information for any other purposes.
- legal or other professional consultants.
We may also disclose aggregated information about our users, and information that does not identify any individual, without restriction. We also may share aggregated information with third-parties for conducting general business analysis. This information does not contain any personal data and may be used to develop content and services that we hope you and other users will find of interest and to target content and advertising.
Please note that we have never sold and will never sell your personal data to third parties.
9. Financial Information
Financial information (including personal information) that you have provided to us will only be shared with our third-party processors in order to initiate and complete any orders placed on your account. All credit card transactions and such are processed with industry standard encryption through third party processors who only use your financial information and personal information for that purpose. All financial data and related personal information will not be shared by us with third parties except with your authorization or when necessary to carry out all and any transactions requested by you with the understanding that such transactions may be subject to rules, terms, conditions and policies of a third party. All such information provided to a third party is subject to their terms and conditions.
10. User’s Profile
Users should be aware that all information directly provided on the LiveXP when they create an account is public and might be viewed by all other Users and Browsers of the LiveXP, unless otherwise stated. Even if a Users’s profile does not contain any personal information, there is a possibility of identification by others through other information on the User’s profile. Accordingly, Users should understand that they are in control of all of the information they upload on the LiveXP and/or display on their profile and are fully responsible for any consequences arising out of such information.
11. User Submissions
12. Security of your personal data
We take appropriate security measures (including physical, electronic and procedural measures) to safeguard your personal data from unauthorized access and disclosure. For instance, only authorized employees are permitted to access personal data, and they may do so only for permitted business functions. In addition, we use encryption in the transmission of your personal data between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your personal data. However, please be advised that we cannot fully eliminate security risks associated with the storage and transmission of personal data as we cannot guarantee that our security measures will prevent third-party hackers from illegally obtaining this information.
You are responsible for maintaining the secrecy of your unique password and account information at all times. We are not responsible for circumventions of any privacy settings or security measures contained on the LiveXP.
13. Marketing information
We may process your personal data so as to inform you about existing and/or future services that may be of interest to you by sending you periodic announcements with details on existing and/or new services and/or programs.
You have the right to object at any time to the processing of your personal data for marketing purposes, by sending us an email at [email protected] or by clicking at the opt-out link at the bottom of any marketing emails we send you.
We can only use your personal data to promote our services to you if we have your explicit consent to do so, or in certain cases such as for example when you are a User of LiveXP, if we consider that it is in our legitimate interest to do so. You may also occasionally receive marketing communications from our affiliates, but only provided you have given your explicit consent in receiving such communications.
Even if you inform us that you no longer wish to receive marketing material, you will still receive from us system notices and other information specifically related to your account from time to time.
14. How long we keep your personal data for
We will only keep your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Where permissible, we will also delete your personal data upon your request. Information on how to make a deletion request can be found under the paragraph “Your data protection rights” below.
If you have questions about our data retention practices, please contact us electronically by sending as an email at [email protected].
15. Your data protection rights
Subject to local law, you have certain rights regarding the personal data we collect, use or disclose and that is related to you. We want to make sure you are aware of your rights in relation to the personal data we process about you. We have described those rights and the circumstances in which they apply further below.
Right to Access: This enables you to get access or receive a copy of the personal data that we hold about you and to check that we are lawfully processing it.
Right to Data Rectification and Correction: If you believe that any of the information that we hold about you is inaccurate or incomplete, you have a right to request that we correct the inaccurate personal information.
Right to be Forgotten / Erasure: You may request that we delete your personal information if you believe that:
- we no longer need to process your information for the purposes for which it was provided;
- we have requested your permission to process your personal information and you wish to withdraw your consent; or
- we are not using your information in a lawful manner.
Right to object: You have the right to object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground. If you exercise your right to object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedom or for the establishment, exercise and defense of legal claims.
You also have the right to object where we are processing your personal data for direct marketing purposes. This also includes profiling in as much as it is related to direct marketing.
If you object to processing for direct marketing purposes, then we shall stop the processing of your personal data for such purposes.
Depending on the circumstances, we may need to restrict or cease processing your personal data altogether or, where requested, delete your personal data. Please note that if you object us processing your personal data, we may have to suspend the services we provide to you.
Right to Restriction of Processing: You have the right to request the restriction of processing of your personal data. This enables you to ask us to restrict the processing of your personal data if:
- it is not accurate; or
- it has been used unlawfully but you do not want us to delete it; or
- it is not relevant any more, but you want us to keep it for use in possible legal claims; or
- you have already asked us to stop using your personal data but you are waiting for us to confirm if we have legitimate grounds to use your personal data.
Please note that if you request us to restrict processing of your personal data, we may have to suspend the services we provide to you.
Right to data portability: Where we have requested your permission to process your personal data or you have provided us with information for the purposes of entering into a contract with us, you have the right to receive the personal data you provided to us in a portable format. You may also request us to provide it directly to a third party, if technically feasible. We are not responsible for any such third party’s use of your account information, which will be governed by their agreement with you and any privacy statement they provided to you.
If we ask for your consent to use your personal data, you can withdraw your consent at any time. Please note that in case of a withdrawal of your consent you may no longer be able to use several functionalities of LiveXP and our services.
Please note that some requests to delete certain personal data will require the deletion of your account as a User as the provision of User accounts is inextricably linked to the use of certain personal data (e.g. your email address). Also note that it is possible that we require additional information from you in order to verify your authorization to make the request and to honor your request.
To exercise any of your rights, or if you have any other questions about our use of your personal data, please contact us electronically by sending us an email at [email protected] or by post at 12 Chrysanthou Mylona, Harmonia Building, Block 1, 1st Floor, Flat 15, 3030 Limassol, CYPRUS.
We endeavor to address all your requests promptly.
16. How to access or modify your personal data
We remain dedicated to the protection of your data and we want to be clear about the type of information collected, helping you make choices about your privacy. You may:
- access/modify the information in your profile provided during registration.;
- choose whether your profile/uploaded content is visible to everyone, or to other Users;
- control who you disclose the information to through social networks, comments and PMs on the LiveXP; or
- block cookies, including cookies associated with our services, by activating or deactivating the related cookies on your browser. Please note, however, that if you choose to disable all cookies (including essential cookies) you may not be able to access all or part of LiveXP. Please see our Cookies Policy for more information.
17. Choices About How We Collect, Use and Disclose Your Personal Information
We strive to provide you with choices regarding the personal information you provide to us.
You can choose not to provide us with certain personal information, but that may result in you being unable to use certain features of LiveXP because such information may be required in order for you to register as a User; purchase products or services; participate in a contest, promotion, survey; ask a question; or initiate other transactions on LiveXP.
You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. Please see our Cookies Policy for more information.
When you register on LiveXP, you may be given a choice as to whether you want to receive email messages, newsletters or both about product updates, improvements, special offers, or containing special distributions of content by us. If you no longer want to receive commercial or promotional emails or newsletters from us, you will need to avail yourself of the unsubscribe mechanism set out in the applicable communication. It may take up to seven days for us to process an opt-out request. We may send you other types of transactional and relationship e-mail communications, such as service announcements, administrative notices, and surveys, without offering you the opportunity to opt out of receiving them. Please note that opting out of receipt of promotional email communications will only affect future activities or communications from us. If we have already provided your information to a third party before you have changed your preferences or updated your information, you may have to change your preferences directly with that third party.
You may opt out of interest-based advertising on mobile devices by activating the “Limit Ad Tracking” or equivalent feature offered by your mobile platform. It will transmit a signal to us and to third-parties that indicates your data should not be used for interest-based advertising.
If you submit personal information, you may delete your account with us at any time. If you delete your account, your Personal Information and any and all other account related information including, but not limited to, user profile data, sharing data and any other data, or content specifically associated with your account will no longer be accessible by you. After deleting your account, if you choose to have an account with us in the future, you will have to sign up for a new account as none of the information you previously provided or saved within your account will have been saved.
18. Our communication with you
19. Right to complain
If you wish to lodge a complaint about how your personal data is used by the Company, you may contact us electronically at the email address [email protected] or by post at 12 Chrysanthou Mylona, Harmonia Building, Block 1, 1st Floor, Flat 15, 3030 Limassol, CYPRUS.
Upon receipt of your complaint, we will investigate it and respond to you within a reasonable time.
We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the collection, use and disclosure of personal data that cannot be resolved by an individual and us.
You also have the right to complain to the data protection supervisory authority of the country in which you reside, provided that such country is a Member State of the European Union or is located within the EEA.
20. Our policy towards minors
LiveXP is not directed to individuals under the age of thirteen (13) and we do not knowingly collect personal data from minors under the age of thirteen. For residents of the EEA, where the processing of personal information is based on consent, users between 13 and 16 years old of age should use the LiveXP only subject to parental consent. By continuing using the LiveXP, we assume that the necessary consents by the guardians/parents have been provided. If we learn that we are engaged in that processing with such users without the parental consent, we will halt such processing and will take reasonable measures to promptly remove applicable information from our records If you become aware that your child has provided us with personal data, please contact us electronically at [email protected]. If we become aware that a minor has provided us with personal data, we will take steps to remove such information and terminate that person’s account immediately.
21. Third-party links
22. Third Party Login Functionality
We may permit users with accounts on certain third-party services, including but not limited to, social networking, search, sharing, and other services delivered by third parties, to bypass the standard applicable registration process. If you connect through an authorized third-party service, you will be able to use your third-party login information to log in to your account or access our content. We are not responsible for the sharing, posting, commenting, or other content and information gathering practices of any third-party services that may be triggered by using these third-party login services. Please review their terms of service and privacy policies carefully before using third party login functionality to access LiveXP.
23. California Consumer Privacy Act Notice
As of January 1, 2020, the California Consumer Privacy Act of 2018 (“CCPA”) provides California residents (“Consumer(s)”) certain rights with respect to their personal information, as this term is defined under the CCPA. In addition to the rights we state under this policy and subject to the exceptions found under the CCPA, Consumers have the right to:
Opt-out of the sale of their personal information, should we sell their personal information;
Be informed of certain information concerning our collection and use of their personal information;
Request that we delete certain personal information we collected from them;
Appoint an agent to exercise their rights provided for by the CCPA, provided that a duly executed notarized power of attorney is presented and provided that the agent has information deemed sufficient to allow us to verify the identity of the Consumer in question and to locate his/her information in our systems;
Not be subjected to discrimination for the exercise of these rights. We will not deny California residents the use of our service, neither will we provide a different level or quality or services for exercising any of their CCPA rights, unless as permitted under the CCPA.
LiveXP does not sell nor has it sold in the past 12 months personal information to third parties for monetary or other valuable considerations. We may however disclose certain personal information with third parties, service providers and entities within our corporate group in order to enable them to perform certain services on our behalf and namely to make the LiveXP work properly.
Regardless, we respect the California residents’ right to exclude personal information from such sharing arrangements and to thereby opt-out of any future sale of their personal information. If the CCPA is applicable to you and you would like to record such preference, please send us an email at [email protected].
26. No Error Free Performance