Privacy Policy

Last Updated Nov 6, 2020

This Privacy Policy (“Policy”) applies to services provided by Lowkey Inc.  (“we”, “us”, or “Company”) and our website, product pages, mobile or web applications, or other digital products that link to or reference this Policy (collectively, the “Services”) and explains what information we collect from users of our Services (a “user”, “you”, or “your”), including information that may be used to personally identify you (“Personal data”) and how we use it. We encourage you to read the details below. This Policy applies to any user or visitor to or user of our Services. We reserve the right to change this Policy at any time. We will notify you of any changes to this Policy by posting a new Policy to the Services, and/or by sending notice to the primary email address specified in your account. You should periodically check our website, including this privacy page, for updates. You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Policy means that the collection, use and sharing of your Personal Data is subject to the updated Policy.

Types of Personal Data Collected

We collect the following Personal Data from you:

  • Usage data regarding how you interact with our services.
  • Account registration data, which includes your username, profile picture, age, email address and country.  You may update or correct your account registration data in the Services via your profile.
  • Any other Personal Data that you voluntarily submit to us or provide to the Services.

 

If you sign-up to access the Services via a third party platform, such as Discord, your interactions and any information you provide to the third party will be governed by their respective privacy policies, which we encourage you to review for more information about their data practices. The Discord privacy policy is available at:

 

Personal Data may be freely provided by you, or, in case of usage data, may be collected automatically when you use the Services through the use of tracking technologies as further described in this Privacy Policy. Unless specified otherwise, all Personal Data requested by the Services is mandatory and failure to provide this Personal Data may make it impossible to provide the Services to you. To the extent that you transfer or submit any third-party Personal Data, such as video or image content containing third-party Personal Data,  you are responsible for any third-party Personal Data obtained, published or shared through the Services and confirm that you have the third party's consent to provide their Personal Data to the Company.

 

Use of Tracking Technologies

 

We collect information through the use of “cookies”, web beacons/tracking pixels, log files, data analytics tools like Mixpanel, and other third party technologies to understand how you navigate through and interact with our Services.

 

A "cookie" is a small file placed on your hard drive or device by some of our web pages. We, or third parties we do business with, may use cookies to help us analyze our web page flow, customize our services, content and advertising, measure promotional effectiveness and promote trust and safety. Cookies are commonly used at most major transactional websites in much the same way we use them in our Services. You may delete and block all cookies from our Services, but parts of the Services may not work. To find out how to make these changes to your browser regarding cookies, please visit: www.allaboutcookies.org/manage-cookies/.  Unless you have adjusted your browser settings so that it will refuse cookies, our system will send cookies as soon as you access our Services.  By using the Services you consent to this, unless you change your browser settings.  

 

How Personal Data is Used

We use the information we collect to:

  • Deliver and improve the Services and your overall user experience.
  • To protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.
  • To link or combine user information with other Personal Data.
  • To compare and verify information for accuracy and update our records.
  • Email, text, message, or otherwise contact you with information and updates about us and the Services 
  • To respond to your comments and questions and provide customer service.
  • To send you information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.
  • Analyze how you use the Services with tools such as Mixpanel and other tools to help us understand traffic patterns and know if there are problems with the Services.

 

We will also share Personal Data with companies, organizations or individuals outside of Company if we have a good-faith belief that access, use, preservation, or disclosure of your Personal Data is reasonably necessary to detect or protect against fraud or security issues, enforce our terms of use, meet any enforceable government request, defend against legal claims, or protect against harm to our legal rights or safety.

How Personal Data is Shared

We do not rent, sell, or share your Personal Data with other people or non-affiliated third parties except with your consent or as necessary to complete any transaction or provide any service you have requested or authorized. 

To help us do our work, we may provide limited access to some of your Personal Data to the following third parties:

  • Affiliates: We may share your information with our affiliates and/or subsidiaries.
  • MixPanel:Company utilizes MixPanel for tracking user-driven events in the web application. MixPanel collects information in accordance with its MixPanel Privacy Policy, available at: https://mixpanel.com/legal/privacy-policy/. You can opt-out of MixPanel’s automatic retention of data collected by clicking here: MixPanel Opt-Out.
  • Intercom Chat Widget: Our chat box operates using the Intercom chat widget. In facilitating our communication with you, Intercom may process information about you such as, but not limited to: username, user email address, and internal user ID.
  • Other Service Providers: We work with a wide range of third party providers, notably our database administrators, payment processors, cloud computing services, data analytics, and other application service providers. 

Public and Private Data

 

 

Methods of Processing

The Company takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of Personal Data. The processing of Personal Data is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Company, in some cases, the Personal Data may be accessible to certain types of persons in charge, involved with the operation of the Services (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Company.

Legal Basis of Processing

Our lawful bases for processing Personal Data include instances where:

  • users have given their consent for one or more specific purposes. Note: Under some legislations the Company may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases.
  • provision of Personal Data is necessary for the performance of an agreement with the user and/or for any pre-contractual obligations thereof;
  • processing is necessary for compliance with a legal obligation to which the Company is subject;
  • processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company;
  • processing is necessary for the purposes of the legitimate interests pursued by the Company or by a third party.

 

 

 

 

 

Retention and Storage

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. Therefore:

  • Personal Data collected for purposes related to the performance of a contract between the Company and you shall be retained until such contract has been fully performed.
  • Personal Data collected for the purposes of the Company’s legitimate interests shall be retained as long as needed to fulfill such purposes. You may find specific information regarding the legitimate interests pursued by the Company within the relevant sections of this document or by contacting the Company.

The Company may be allowed to retain Personal Data for a longer period whenever you have given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Company may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

 

You may delete any videos you have uploaded in or to the Services at any time by following instructions provided within the Services. You may also request to delete other Personal Data collected by us by contacting us at [email protected].

How We Respond to Do Not Track Signals

Your browser settings may allow you to automatically transmit a Do Not Track signal to websites and other online services you visit. We do not alter our practices when we receive a Do Not Track signal from a visitor’s browser because we do not track our visitors to provide targeted advertising. To find out more about Do Not Track, please visit http://www.allaboutdnt.com.

Children Under 13

The Services are not directed to individuals who are under age of thirteen (13) and we do not solicit nor knowingly collect Personal Data from children under the age of thirteen (13). If you believe that we have unknowingly collected any Personal Data from someone under the age of thirteen (13), please contact us immediately at [email protected] and the information will be deleted.

A Note to Users Outside the United States

Our Company is based in the United States. The Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Your Personal Data may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Data.

Contact Us

If you have any questions about this Policy, your Personal Data, or the Services, you can contact [email protected]

 

 

Information for EEA Residents

If you are a resident of the European Economic Area (“EEA”), you may exercise certain additional rights regarding your Personal Data processed by the Company. In particular, you have the right to do the following:

  • Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
  • Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
  • Access their Data. Users have the right to learn if Data is being processed by the Company, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
  • Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
  • Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Company will not process their Data for any purpose other than storing it.
  • Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Company.
  • Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

 

 

How to exercise these rights

Any requests to exercise the rights set forth above can be directed to the Company through the contact details provided in this document.