Privacy Policy for Lytte

Privacy Policy

Last updated: 28 Jan 2021

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Personal Data when You use the Platform and Services and tells You about Your rights and how the law protects You.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Lytte AS, Bryggegata 3, 0250 Oslo.

Content refers to content such as text, images, or other information that can be posted, uploaded, linked to or otherwise made available by Users through the Services, regardless of the form of that content.

Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

Customer means the legal entity that enters into an agreement with the Company for delivery of the Services.

Customer Account means a unique account created for an individual Customer on the Platform.

Data Controller refers to the legal entity which alone or jointly with others determines the purposes and means of the processing of Personal Data.

Data Processor means any natural or legal person who processes Personal Data on behalf of a Data Controller.

Data Subject means an individual physical person employed or contracted by the Customer whose Personal Data is processed in connection with the delivery of the Services.

Device means any device that can access the Platform and Services such as a computer, a cellphone or a digital tablet.

Personal Data means any information that relates to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Platform refers to both the Lytte website, accessible from lytte.io and Lytte admin, accessible from admin.lytte.app.

Services refer to the services delivered to the Customer through the Platform, as further described in the Company’s Terms and Conditions.

Usage Data refers to data generated through the use of the Platform and Services (for example, the duration of a page visit).

User or You means you as an individual physical person who accesses the Platform and Services through a Customer Account, whose Personal Data is processed in connection with the delivery of the Services.

Collecting and Using Personal Data

Data Controller and Data Processor

The Company is the Data Controller responsible for the processing of Your Personal Data collected through the Services as further described in this Privacy Policy.

We employ Data Processors to process Your Personal Data on Our behalf. Transfer of Your Personal Data to our Data Processors will be governed by a Data Processing Agreement between Us and the Data Processor.

Types of Personal Data collected

Customer Personal Data

In connection with the creation or maintenance of a Customer Account, We will ask the Customer’s representative to provide Us with certain Personal Data that will be used in connection with Our delivery of Services to the Customer and the Customer’s Users. Such Personal Data will typically include:

  • First and last name(s) of the Customer’s User(s)
  • First and last names of the Users to whom the Customer will provide access to the Platform and Services through the Customer Account
  • Contact data relating to the Customer’s representative(s) and Users, such as Email addresses and Phone numbers

We will also collect and store Personal Data about You contained by the Content that You or any other User enters into the Platform and Services.

Usage Personal Data

Usage Personal Data is collected automatically during Your use of the Platform and Services. Such data will include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect further Personal Data, including the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Cookies

We use Cookies and similar tracking technologies to track Your activity on the Service and to collect and store Usage Personal Data. The technologies We use to improve and analyze Our Service include:

  • Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You refuse necessary/essential cookies, You will not be able to use our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

We use both Session and Persistent Cookies for the purposes set out below:

Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookies are essential to provide You with Services available through the Platform and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these cookies, the Services that You have asked for cannot be provided, and We only use these Cookies to provide You with those Services.

Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies identify if users have accepted the use of cookies on the Platform.

Functionality Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies allow us to remember choices You make when You use the Platform, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Platform.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

To provide and maintain our Service, including to deliver to You and other Users under your Customer Account any products, or Services You or the Customer has purchased, as well as to monitor Your usage of our Platform and Services.

To manage the Customer Account: to manage Your registration as a user of the Platform and Services. The Personal Data You provide can give You access to different functionalities of the Platform and Services that are available to You as a registered user.

To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted Services, including the security updates, when necessary or reasonable for their implementation.

To manage Your requests: To attend and manage Your requests to Us.

For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Platform and Services Users is among the assets transferred.

For product development purposes: We may use Your information to develop and improve our products, through data analysis, research, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Platform and Services, products, marketing and Your experience.

We may share Your personal information in the following situations:

  • With service providers: We may share Your personal information with Our service providers to monitor and analyze the use of our Platform and Services, and for payment processing.
  • For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
  • With affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
  • With partners: We may share Your information with Our partners to offer You certain products, services or promotions; and for research development purposes.
  • With other Users: when You share Personal Data through the Platform and Services, we may share such Personal Data with other Users linked with the same Customer Account. When You share Personal Data through or otherwise interact in the public areas with other Users, such information may be viewed by all Users and may be publicly distributed.
  • With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Payments

We may provide paid products and/or services within the Platform and Services. In that case, we may use third-party services for payment processing (e.g. payment processors).

We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

When You use Our Platform and Services to pay a product and/or service via bank transfer, We may ask You to provide information to facilitate this transaction and to verify Your identity.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis or research purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices, at the offices of our Data Processors and in any other places where the other parties involved in the processing are located. It means that the Personal Data may be transferred to — and maintained on — computers located outside of Your country, where the data protection laws may differ than those from Your jurisdiction.

Some of the recipients to whom your Personal Data will be disclosed, are located outside the European Economic Area, in countries which do not provide the same level of protection to Personal Data. Whether the Personal Data You provide to us is processed by Us or by third parties within the EEA or outside of it, We will take all steps reasonably required to ensure that Your Personal Information is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are appropriate safeguards in place and on condition that enforceable data subject rights and effective legal remedies for data subjects are available. Such appropriate safeguards may be in the form of an agreement based on the standard data protection clauses adopted by the EU Commission.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Legal obligation

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court of law or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect the Company against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Legal Basis for Processing of Your Personal Data

We may process Personal Data under the following legal basis:

  • Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
  • Compliance with legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
  • Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company or by a third party, and the legitimate interests are not overridden by Your interests or fundamental rights and freedoms.
  • Consent: You have given consent to the processing for one or more specific purposes.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights

You have the right under this Privacy Policy to:

  • Right of access to Your Personal Data. You shall have the right to access the Personal Data that We are processing about You, and the following information: The purposes of the processing, the categories of Personal Data concerned, the recipients or categories or recipient to whom the Personal Data have been or will be disclosed.
  • Right to rectification. You have the right to have any incomplete or inaccurate Personal Data We hold about You corrected.
  • Right to object. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
  • Right to erasure. You have the right to ask Us to delete or remove Personal Data when We have no legal basis for the continued processing of such Personal Data.
  • Right to restriction of processing. You shall have the right to obtain from Us restriction of processing where the accuracy of the Personal Data is contested by You, where the processing is unlawful and You oppose the erasure of the Personal Data and request the restriction of their use instead, where We no longer need the personal data, but they are required by You for the establishment, exercise or defense of legal claims, or where You have objected to processing, pending the verification whether Our legitimate grounds override those of the Data Subject.
  • Right of data portability. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.

Exercising of Your Rights

You may exercise Your rights of access, rectification, cancellation, objection, erasure, restriction and data portability by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a competent Data Protection Authority about Our collection and use of Your Personal Data. For more information, please contact the data protection authority in Norway, which is Datatilsynet, P.O. Box 458 Sentrum, 0105 Oslo, Norway, telephone number +47 22 39 69 00. If you are located in another country within the EEA, you may instead contact your local Data Protection Authority.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on our Platform.

We will let You know via email and/or a prominent notice on our Platform or Services, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us by email: [email protected]